PRIVACY POLICY | KnowKnow

Data Controller: Retower Tech PTE. LTD. (“Company”, “we”, “us”, or “our”)

Data Protection Officer (DPO): dpo@knowknow.app

This Privacy Policy explains how the Knowknow application (the “Service”) collects, uses, and protects your personal data. This Privacy Policy is incorporated into and forms part of our Terms of Service. By using the Service, you consent to the collection and processing of your information as described in this policy.

1. INFORMATION WE COLLECT

We collect only the information necessary to provide and improve our AI-driven information reference service:

Account Data: Email address, registration timestamp, and profile settings.
Technical Data: IP address, device type, operating system version, and app usage statistics (e.g., feature interactions and performance logs).
User Content: Photos you voluntarily upload (e.g., food images), lifestyle entries (e.g., weight, diet logs), and chat history with the AI. If you choose to connect Apple Health or Health Connect, this also includes health and fitness data synced from those platforms (see Section 3).
PROHIBITION: We strictly prohibit the upload of sensitive medical data, including medical records, clinical reports, or prescriptions. Any such unauthorized uploads are subject to the terms in Section 5.

2. HOW WE USE YOUR INFORMATION

We process your data for the following legitimate purposes:

Service Delivery: To perform AI image recognition and generate health/lifestyle information reference reports.
Customer Support: To respond to inquiries and technical issues via our support channels.
AI Optimization: • As of the Effective Date, the Company does not use User Content to train AI models. If the Company decides to use anonymized and aggregated User Content for model improvement in the future, we will: (a) notify you at least 30 days in advance via in-app notification or email; and (b) provide a clear opt-out mechanism in the App settings. Only data from users who have not opted out will be used. See Section 7.3 of our Terms of Service for details. For clarity, health and fitness data obtained from Apple Health or Health Connect is excluded from AI model training and model improvement, except where such data is de-identified and aggregated and used solely to improve the health features described in Section 3, subject to the notice and opt-out mechanism described above.
Legal Compliance: To fulfill regulatory obligations or respond to lawful requests from authorities.

3. HEALTH AND FITNESS DATA (Apple Health / Health Connect)

If you choose to connect the Service to Apple Health (HealthKit) or Android’s Health Connect, we read the following data only after you grant explicit permission through the operating system’s authorization interface:

Body measurements: Weight and height.
Daily activity summaries: Step count and active energy burned.
Workout records: workout type, start and end times, duration, and energy burned.

With respect to this data, we commit to the following:

3.1 Purpose of Use: This data is used solely to provide features to you — displaying trends and daily activity in the App, and informing your personalized nutrition advice and AI analysis. To generate AI advice, aggregated activity figures (such as daily step counts) may be transmitted to AI service providers as described in Section 6.1; providers may process the data only to deliver that service.

3.2 Limited Use Commitment: We do not use health and fitness data for advertising or marketing, do not sell it, and do not use it for any purpose other than those described in this Section.

3.3 Storage: Synced data is transmitted to our servers and stored in association with your account so it is available across your devices, protected by the safeguards described in Section 4 (Cross-Border Data Transfer).

3.4 Your Controls: You may stop syncing at any time via Settings > Health Data Sync in the App, and revoke access in the iOS Health app or Android’s Health Connect settings. When you delete your account, synced health data will be deleted or irreversibly anonymized, typically within 30 days, except where retention is required by law, as described in Sections 7 and 8.

3.5 Relationship to the Section 1 Prohibition: Weight, height, and activity data synced through this mechanism are lifestyle data the Service is designed to support; they are not the prohibited sensitive medical data (e.g., medical records, clinical reports, prescriptions) described in Section 1.

4. CROSS-BORDER DATA TRANSFER

To provide high-performance AI analysis, your data is securely transferred and processed across:

Singapore: Our global headquarters for operations and data control.
Taiwan: Our core technical R&D and customer support center.
United States: Our primary AI model providers and cloud infrastructure providers.

Security Commitment: All transfers are protected by appropriate technical and organizational security measures. We ensure that your data receives a protection level comparable to the requirements of the Singapore PDPA and other applicable laws.

5. Prohibited Uploads and Data Handling

Knowknow is an information reference tool, not a medical diagnostic service.

5.1 The Service is not designed to store or process clinical medical records, and should not be used as a repository for your medical records. With respect to personal data that we do in fact hold, we apply appropriate technical and organisational security measures in accordance with applicable law (see Section 4).

5.2 No Proactive Screening. We are under no obligation to monitor, review, or screen User Content for the purpose of detecting violations of the prohibition in Section 1. You are responsible for ensuring that the content you upload does not contain sensitive medical data, including medical records, clinical reports, or physicians’ prescriptions. However, where we obtain actual knowledge — whether by report or otherwise — that you have uploaded such data, we will handle it in accordance with Section 5.3.

5.3 Handling Upon Actual Knowledge. Upon becoming aware that a user has uploaded data prohibited under Section 1, we will: • (a) promptly restrict access to that data to personnel who require it in order to address the matter • (b) cease using that data for AI analysis, model improvement, or any transfer to third parties; • © securely delete it once any necessary verification is complete, ordinarily within 30 days; and • (d) where that data has been, or is suspected of having been, subject to unauthorised access, loss, or disclosure, notify affected users and report to the competent authorities in accordance with Section 9. 5.4 Responsibility. You bear the risk arising from uploading data in breach of the prohibition in Section 1.

6. Sharing with Third Parties

We do not sell or rent your personal data. We only share data with trusted partners to facilitate the Service:

6.1 AI Service Providers: User Content may be transmitted to third-party AI model providers solely to generate analysis and responses for you; health and fitness data, however, may be transmitted only to the limited extent expressly described in Section 3.1. Before transmission, we apply de-identification measures where technically feasible. We require our AI service providers to commit to appropriate data protection obligations, whether through Data Processing Agreements, their standard terms of service, or equivalent contractual safeguards.

6.2 Cloud Infrastructure Providers

Data is stored on secure cloud servers provided by industry-leading infrastructure providers. These providers act as sub-processors under our direction and are bound by contractual obligations to protect your data.

6.3 Legal Necessity

We may disclose data if required by law, regulation, or legal process, or to protect the safety and rights of our users and the Company.

7. YOUR RIGHTS AND ACCOUNT DELETION

Under applicable laws (e.g., Singapore PDPA, Taiwan PDPA), you have the right to access, correct, or delete your data.

7.1 Account Deletion (App Store Compliance)

In compliance with mobile platform policies, you may permanently delete your account at any time:

In-App Path: Navigate to Settings > Account Security > Delete Account.
Manual Request: You may also email dpo@knowknow.app to request data removal.

7.2 Impact of Deletion

Data Removal: Upon confirmation, your profile and history will be permanently deleted or anonymized (except where retention is legally required).
SUBSCRIPTION NOTICE: Deleting your account does NOT automatically cancel your App Store or Google Play subscriptions. You must manually cancel the subscription in your platform settings to stop future charges.

8. DATA RETENTION

We retain your personal data only for as long as necessary to provide the Service. Once your account is deleted, your data will be purged from our active databases within a reasonable timeframe (typically within 30 days), subject to legal retention requirements.

9. Data Breach Notification

In the event of a data breach that affects your personal data, the Company will:

• Notify affected users without undue delay and in accordance with applicable law;

• Notify relevant regulatory authorities as required by applicable data protection laws (e.g., Singapore PDPC, Taiwan PDPA authorities);

• Take immediate steps to contain the breach and mitigate any potential harm.

10. Additional Notice for U.S. Residents

This section applies to residents of U.S. states with comprehensive privacy laws, including California, Virginia, Colorado, Connecticut, and Utah.

10.1 Notice at Collection

In the preceding 12 months, we have collected the following categories of personal information as defined by applicable U.S. state privacy laws:

• Identifiers: Email address, IP address, and unique device identifiers.

• Commercial Information: Subscription records and transaction timestamps.

• Internet or Other Electronic Network Activity: App interaction logs, feature usage data, and performance statistics.

• Inferences: Lifestyle and health-related preferences derived from your voluntarily provided diet and exercise logs.

• Sensitive Personal Information: Health and fitness data (weight, height, step counts, active energy) that you affirmatively choose to sync from Apple Health or Health Connect, used solely as described in Section 3.

These categories are collected for the business purposes outlined in Sections 2 and 3 of this Privacy Policy, as applicable.

10.2 Your Privacy Rights

Depending on your state of residence, you may have some or all of the following rights:

• Right to Know and Access: Request disclosure of the categories and specific pieces of personal data we have collected about you.

• Right to Delete: Request the deletion of your personal data, subject to certain legal exceptions.

• Right to Correct: Request the correction of inaccurate personal information.

• Right to Opt-Out of Sharing: We do not sell your personal information for monetary consideration. You have the right to opt out of the sharing of your information for cross-context behavioral advertising.

• Right to Limit Use of Sensitive Personal Information: You may request that we limit the use of sensitive personal data to that which is necessary to provide the Service.

• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

• Right to Appeal: If we deny your privacy request, you may appeal our decision by contacting dpo@knowknow.app. We will respond to your appeal in accordance with applicable law.

10.3 No Sale of Personal Information

Retower Tech PTE. LTD. has not sold any personal information to third parties for monetary or other valuable consideration in the preceding 12 months.

10.4 Children’s Privacy (COPPA)

The Service is not intended for children under 13. We do not knowingly collect personal information from children under 13. If we discover such data has been collected, we will take immediate steps to delete it from our servers. If you believe a child under 13 has provided us with personal information, please contact us at dpo@knowknow.app.

10.5 Exercising Your Rights and Verification

To exercise your rights, please contact dpo@knowknow.app. To protect your privacy, we will verify your identity before fulfilling your request. Verification may require you to provide the email address associated with your account and confirm certain account activities. You may also designate an authorized agent to make a request on your behalf.

11. CONTACT OUR DATA PROTECTION OFFICER (DPO)

If you have questions regarding this policy or wish to exercise your privacy rights, please contact our DPO at: dpo@knowknow.app.

Governing Language

This Privacy Policy is executed in English. Translations are provided for convenience only; in the event of any inconsistency between the English version and a translation, the English version shall prevail.