Privacy Policy

MATTER is a space for health optimisation — to help you rest, regenerate, and realign. This Privacy Policy (“Policy”) sets out how we collect, use, and protect your personal data when you access our space, offerings, or platforms. By engaging with MATTER, you’re trusting us with your information — and we take that responsibility seriously.

Please read this Policy carefully to understand how your data is handled when you use any of our Services.

1. OVERVIEW & ACCEPTANCE

1.1 Scope

This Policy applies to your access to and use of all services, premises, locations, websites, booking systems, communications, and offerings provided by Regenerative Health Asia Pte. Ltd., trading as MATTER (“MATTER”, “we”, “us”, or “our”) (collectively, the “Services”), whether in person or online. It also covers all Personal Data in our possession or under our control, including data held by third parties we work with to support service delivery, research, administration, compliance, or operations.

This Policy applies to data collected when you:

• Visit our premises or use any part of our space, including wellness areas, lounges, or consultation rooms;
• Make bookings through our website, app, third-party booking platforms, or in person;
• Attend sessions, wellness treatments, medical consultations, or other in-person services;
• Submit intake forms, health declarations, medical history, consent waivers, or pre-treatment screening questionnaires;
• Interact with our website, app, email communications, or other digital platforms;
• Engage with us through social media, surveys, feedback forms, or research initiatives;
• Communicate with our staff, contractors, healthcare practitioners, or affiliated partners — whether in person, over email, or through other channels;
• Participate in or inquire about services such as sauna, cold plunge, IV vitamin therapy, osteopathy, red light therapy, cryotherapy,hyperbaric oxygen therapy (HBOT), or practitioner-led health consultations;
• Apply for employment, contracting, or practitioner roles at MATTER;
• Provide services to us as a vendor, supplier, or professional advisor, or act on behalf of a business interacting with MATTER; and
• Are captured in CCTV footage while on our premises or surrounding areas.

This Policy applies in addition to any other waiver, release form, agreement, or terms you enter into with MATTER.

1.2 Changes to Terms

We may update or amend this Policy at any time, at our sole discretion. The latest version will always be available at www.matterlife.co.

You are responsible for reviewing the most current version. By continuing to use our Services after any updates are posted, you agree to the revised Policy. If you do not agree with the changes, you should stop using our Services and may contact us to withdraw your consent where applicable.

1.3 Acceptance

By visiting a MATTER location, using our premises, booking a session, submitting personal data, or engaging with any of our Services, you confirm that you have read, understood, and agreed to the terms of this Policy.

Where you provide us with any health, medical, or other sensitive personal data — including through intake forms, consultations, treatments, or communications with our team — you expressly consent to the collection, use, and disclosure of that information in accordance with this Policy, including disclosure to registered medical practitioners and third-party service partners who support or deliver part of our integrated care model.

2. YOUR PERSONAL DATA MATTERS

2.1 What is Personal Data

“Personal Data” refers to data, whether true or not, about an individual who can be identified:
(i) from that data; or (ii) from that data and other information to which we have or are likely to have access.

This includes data that is protected under the Personal Data Protection Act 2012 of Singapore. Examples include your name, contact details, medical information, session history, and anything else that can be linked to you as an individual.

2.2 How We Collect Personal Data

We collect Personal Data through your interactions with us — both online and in person. This includes data you provide directly, data we generate through the course of delivering our Services, and data we receive from third parties.

Personal Data may be collected when you:

• Visit our premises or use any part of our space, including wellness areas, lounges, or consultation rooms;
• Make bookings through our website, app, third-party booking platforms, or in person;
• Attend sessions, wellness treatments, medical consultations, or other in-person services;
• Submit intake forms, health declarations, medical history, consent waivers, or pre-treatment screening questionnaires;
• Interact with our website, app, email communications, or other digital platforms;
• Engage with us through social media, surveys, feedback forms, or research initiatives;
• Communicate with our staff, contractors, healthcare practitioners, or affiliated partners — whether in person, over email, or through other channels;
• Participate in or inquire about services such as sauna, cold plunge, IV vitamin therapy, osteopathy, red light therapy, cryotherapy, hyperbaric oxygen therapy (HBOT), or practitioner-led health consultations (which include, but are not limited to, consultations or sessions delivered by health coaches, medical doctors, nurses, mental health practitioners, physiotherapists, osteopaths, or other qualified health or wellness professionals);
• Apply for employment, contracting, or practitioner roles at MATTER;
• Provide services to us as a vendor, supplier, or professional advisor, or act on behalf of a business interacting with MATTER; and
• Are captured in CCTV footage while on our premises or surrounding areas.

We may also collect Personal Data indirectly:

• From third-party platforms used to manage bookings, communications, or payments;
• From external healthcare or wellness partners as part of our integrated care model; and/or
• From publicly available sources, social media, or business directories.

2.3 Types of Personal Data We May Collect

The types of Personal Data we may collect include (but are not limited to):

• Identity and contact information: Name, email, phone number, mailing address;
• Health and medical information: Health status, medical history, medications, allergies, practitioner notes, and treatment records;
• Booking and usage data: Session history, services used, appointment preferences;
• Payment and transaction data: Billing information, payment confirmations (we do not store full credit card numbers);
• Device and interaction data: IP address, device type, browser settings, cookies, and usage analytics;
• Marketing and communication preferences: Campaign engagement, opt-in/opt-out status;
• Survey and research responses: Feedback provided as part of client experience or research activities;
• Employment or contractor data: Resumes, qualifications, references, and work history; and/or
• Third-party relationship data: Information about individuals connected to vendors, partners, or advisors.

We only collect Personal Data that is reasonably necessary for the purposes described in this Policy, or where required or permitted by law.

2.4 If You Provide Personal Data About Others

If you provide us with Personal Data relating to another individual (such as a family member, guest, employee, or someone you represent), you confirm that:

• You have obtained their consent to do so;
• You have informed them of the contents of this Policy; and
• You are authorised to provide their Personal Data to us for the purposes described here.

You represent and warrant that all Personal Data you provide — whether about yourself or others — is accurate, complete, and submitted in accordance with applicable law

2.5 Personal Data of Minors

If you are aged 16 to 18, access to certain MATTER services or areas of our premises may require the consent of a parent or legal guardian. If Personal Data is submitted on behalf of a minor in this age group, the individual providing the data confirms that they are the minor’s parent, legal guardian, or authorised representative, and that they consent to the collection, use, and disclosure of the minor’s Personal Data as set out in this Policy.

3. HOW YOUR DATA MATTERS TO US

3.1 Purpose of Use

We use your Personal Data to operate, support, and improve the Services offered by MATTER, including both wellness and medical services provided at our premises or through our platforms. This includes delivering treatments, managing bookings, maintaining client records, and operating our day-to-day business.

Your Personal Data may be used to:

• Provide wellness and medical treatments, consultations, and follow-up care;
• Assess your suitability for specific services based on your health disclosures or treatment history;
• Maintain intake forms, health declarations, practitioner notes, and other records;
• Manage bookings, session history, payment records, and membership status;
• Communicate with you about appointments, updates, or administrative matters;
• Send marketing communications, promotions, or personalised content (with your consent);
• Collect and analyse feedback or survey data to improve our Services;
• Monitor and enhance safety, experience, and functionality across our premises and digital platforms;
• Support internal operations, such as audits, billing, training, and quality control;
• Process job applications and manage employment or contractor relationships;
• Comply with legal, regulatory, and clinical obligations; and
• Enforce our Terms of Service, house rules, waivers, or other agreements.

We may also use your Personal Data to generate aggregated or anonymised data for research, reporting, or analytics. Once anonymised, this data is no longer considered Personal Data and is excluded from this Policy.

3.2 How We Process Personal Data

“Processing” refers to any handling of Personal Data, whether by electronic or physical means. This includes collecting, recording, organising, storing, accessing, using, reviewing, updating, transmitting, disclosing, archiving, anonymising, or deleting data.

We process your Personal Data in a manner that is:

• Reasonable and proportionate to the purpose for which it was collected;
• Secure and protected from unauthorised access or misuse;
• Limited to the extent necessary to deliver or support our Services; and
• In line with your consents, legal obligations, and applicable privacy regulations.

Sensitive Personal Data — including health or medical information — is only processed with your explicit consent or where permitted by law.

If you withdraw your consent to certain uses of your Personal Data (e.g. marketing communications), we will update our records accordingly. Some uses, such as regulatory or safety-related processing, may continue where required by law.

3.3 Joint or Partner Processing

Where MATTER works with external partners, including registered medical practitioners, clinics, or service collaborators, we may share and jointly process Personal Data for the purposes of integrated care, treatment coordination, research, analytics, or service improvement. These partners may include medical clinics, health optimisation providers, or other practitioners involved in delivering part of your MATTER experience.

We take steps to ensure that any such processing is done in accordance with applicable law, your consents, and our data protection standards. Depending on the relationship, these partners may process Personal Data either on our behalf, or as independent data controllers.

4. DATA DISCLOSURE MATTERS

4.1 Disclosure of Personal Data

We may disclose your Personal Data to third parties where reasonably necessary to deliver our Services, support our operations, or comply with legal obligations. Disclosures are made only where appropriate safeguards are in place and consistent with the purposes described in this Policy.

Your Personal Data may be disclosed to:

• Internal personnel: Employees, contractors, registered medical practitioners, or other authorised individuals within MATTER who require access to deliver services or carry out internal operations;
• External service providers: Third parties who support MATTER’s operations, including payment processors, booking platforms, IT service providers, cloud storage providers, analytics vendors, and marketing platforms;
• Healthcare partners and collaborators: Registered medical practitioners, clinics, or external health service providers who work with MATTER to deliver integrated care, diagnostics, or treatments. This includes both on-site and off-site practitioners, and applies whether the practitioner is employed by MATTER or engaged independently;
• Professional advisors: Legal, tax, audit, compliance, and insurance consultants engaged by MATTER.
• Regulatory authorities or law enforcement: Where required to comply with applicable law, legal processes, court orders, or government requests;
• Research and analytics partners: Where data is used in de-identified or aggregated form for evaluation, reporting, or product development; and
• Successors or acquirers: Any actual or potential buyer, investor, or acquiring party (and their advisors) in connection with a business transfer, merger, or sale involving MATTER.

Where Personal Data is shared with third-party partners, we ensure that they are bound by appropriate confidentiality and data protection obligations. These partners may act as independent or joint data controllers depending on the nature of the engagement.

We do not sell or rent your Personal Data to any third party.

4.2 Cross-Border Transfers

Where your Personal Data is transferred outside of Singapore — for example, to cloud service providers or third-party partners located overseas — we will ensure that the receiving party provides a standard of protection comparable to the requirements under the Personal Data Protection Act 2012 (PDPA). This includes putting in place appropriate contractual terms, safeguards, or reliance on statutory exemptions where applicable.

5. RETENTION OF PERSONAL DATA

5.1 How Long We Keep Your Data

We retain your Personal Data only for as long as reasonably necessary to fulfil the purposes for which it was collected, or to satisfy legal, regulatory, clinical, or operational requirements.

This includes retention to:

• Provide ongoing services and maintain treatment records;
• Support medical continuity of care;
• Comply with legal, tax, or regulatory obligations;
• Handle internal audits, incident follow-up, or dispute resolution; and
• Improve MATTER’s services through analytics or research (where anonymised or aggregated).

If you stop using MATTER’s services, we may retain limited data as required by law or where we have a continuing legitimate interest.

5.2 What Happens After That

When your Personal Data is no longer required, we will:

• Anonymise the data so it can no longer be used to identify you; or
• Delete or destroy it using secure methods that are appropriate for the format and sensitivity of the data.

Where third-party vendors store or process data on our behalf, we ensure they are contractually bound to apply similar deletion or anonymisation processes when instructed.

6. DATA SECURITY MATTERS

6.1 Data Security & Security Measures

We implement reasonable administrative, technical, and physical safeguards to protect your Personal Data against unauthorised access, loss, misuse, alteration, or destruction.

These measures are regularly reviewed and updated to ensure they remain appropriate to the sensitivity of the data and the evolving risk landscape. Where we work with third-party vendors or service providers, we ensure they are contractually bound to maintain similar standards of data protection.

6.2 Data Breach Notification

In the event of a data breach that results in, or is likely to result in, significant harm to you, we will:

• Assess and contain the breach promptly;
• Notify the affected individuals as soon as practicable;
• Report the breach to the Personal Data Protection Commission (PDPC) where required; and
• Support any necessary remedial action to reduce or manage harm.

Where applicable, we may also rely on an internal incident response protocol to investigate, document, and mitigate future risks arising from a breach.

7. RIGHTS THAT MATTERS

7.1 Your Rights

You have certain rights under Singapore’s Personal Data Protection Act (PDPA). Subject to applicable exceptions, you may:

• Access the Personal Data MATTER holds about you;
• Request correction of any inaccurate or incomplete data;
• Withdraw your consent to our continued use or disclosure of your Personal Data;
• Object to specific types of processing, such as marketing or analytics; and
• Raise a complaint about how we handle your Personal Data.

7.2 Submitting a Request

To submit a request or make a complaint, please email our Data Protection Officer, details of which are set out below. We may require you to verify your identity and/or provide supporting information. A reasonable administrative fee may apply for access requests, and we will inform you of the cost before processing.

7.3 Impact of Withdrawal of Consent

Please note:

• Withdrawing consent may impact your ability to use certain Services, especially where your Personal Data is necessary for treatment, safety, or legal compliance.
• We may retain certain data where required by law or where we have a legitimate purpose (e.g. clinical recordkeeping, dispute resolution, or fraud prevention).

If withdrawing your consent limits or prevents your access to our Services, you will not be entitled to any refund, credit, or other form of compensation for any unused portion of your membership, sessions, or Services.

7.4 Processing Without Consent

In certain limited circumstances, MATTER may collect, use, or disclose your Personal Data without your consent where required or permitted by law. This includes situations such as:

• Responding to emergencies;
• Complying with regulatory requirements;
• Preventing fraud or misuse; and
• Ensuring the safety and well-being of individuals on our premises.

8. GENERAL TERMS THAT MATTER

8.1 Use of Website and Cookies

When you visit our website or interact with our digital platforms, we may use cookies and similar technologies to enhance functionality, analyse usage, and support service improvement. These may be set by us or third-party service providers (such as analytics or booking platforms).

You can control or disable cookies through your browser settings. If you have any questions about our use of cookies or tracking tools, please contact us via our Data Protection Officer, details of which are set out below.

8.2 Third-Party Platforms and Services

Our Services may involve the use of third-party platforms — such as booking systems, payment gateways, or social media. These services are governed by their own privacy policies and terms. We encourage you to review those policies before submitting your Personal Data through external platforms.

8.3 Data Protection Officer

If you have any questions, concerns, or requests related to this Policy or the handling of your Personal Data, you may contact our Data Protection Officer (DPO) at:

Concierge@matterlife.co

We will respond to your query in accordance with the requirements of Singapore’s Personal Data Protection Act (PDPA).