WelLink App- Privacy Notice - v1.0

WelLink

Privacy Notice

Last Updated: 25.11.2025

 

  1. Who we are and what we do

Who we are

AL-HALLOUL RAQMIYAH Medical (One Partner) (“AL-HALLOUL”, “us”, “we”, “our”) is a limited company registered in Kingdom of Saudi Arabia. Our registered office is 2550 Ismail Al Muzni St., 7757 Az Zahra Dist., Jeddah, Saudi Arabia, 23522. Contact details: Info@ddelmar.ai.

 

What we do

We provide a fitness and wellbeing platform „WelLink“, that allows you to track your activity, daily exercise, and general wellbeing. We are committed to protecting your privacy and the security of any Personal Data we process about you.

 

  1. Purpose of this privacy notice

The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.

 

  1. Who this privacy notice applies to

This privacy notice applies to you if:

  1. You use our App
  2. You sign up to receive newsletters and/or other promotional communications from us
  3. What Personal Data is

‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.

‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation. 

  1. Personal Data we collect

The type of Personal Data we collect about you will depend on our relationship with you. Below is an example of the different categories of personal data we may collect and process about you, when you create an account with us and use our fitness band.

 

  1. Full name
  2. Date of Birth
  3. Email Address
  4. Weight, height, age, body mass index (BMI), and body weight
  5. Payment information
  6. Location information (e.g., country of residence, time zone, and GPS data)
  7. Health information: heart rate, resting heart rate, heart rate variability
  8. Usage information: movement data, goals, activity, sleep, oxygen saturation, and calories burned
  9. Device information in relation to devices you’ve connected.

 

  1. How we collect your Personal Data & the use of Third-Party Services

We collect most of the Personal Data directly from you in person, via our app and your connected devices. We use different third-party service providers to collect personal data including (but not limited to) cookies, web beacons, advertising and analytics tools and software development kits “SDKs”. Rolla Holdco Ltd are the makers of the app you’re using, this means they are our data processor and handle your personal data on our behalf/under our instruction.

 

To provide you with the best possible experience and improve our application, we may partner with the following third-party vendors:

 

  1. Google Analytics – analytics tool used for web & app tracking.
  2. Mixpanel – analytics tool used to understand your in-app behavior.
  3. Adjust – mobile measurement partner that allows us to understand campaign performance.
  4. Other partners
  5. How we use your personal data & the lawful basis for processing

Applicable Data Protection legislation requires us to identify appropriate lawful bases for processing your personal data. The lawful basis we rely on as a data controller are detailed below with brief examples for when they may apply:  

 

Lawful Basis

Purpose/Type of Processing

Performance of Contract

To provide you with our services, we process information relating to you to facilitate your use of our fitness tracker app, such as the information you provide when registering an account. This also includes sending you communications around updates, security alerts and customer support messages.

Legitimate Interests

To monitor and analyse trends, across web and app usage/activities. As well as personalise and improve your web & app experience.

Consent

To communicate with you about products and services we offer, or to share your personal data with third parties when taking part in challenges.

Explicit Consent

We rely on your explicit consent to process your special category personal data when using the app, this enables you to use features that involve your health data, such as health plans.

  1. International Transfers

Your Personal Data may be processed outside the Kingdom of Saudi Arabia. This is because some of the service providers we use to operate and support the app are located outside the Kingdom of Saudi Arabia.

Where we transfer your Personal Data outside Kingdom of Saudi Arabia, we do so in accordance with the requirements of the Saudi Personal Data Protection Law (PDPL) and its implementing regulations. This includes ensuring that:

  1. The country or organisation receiving your Personal Data provides an appropriate level of protection for your Personal Data; or
  2. Appropriate contractual safeguards are in place, such as data transfer agreements incorporating legally-required protections and any additional safeguards required by the PDPL or other applicable laws are implemented.

 

We also ensure that any parties receiving your Personal Data outside Kingdom of Saudi Arabia are subject to confidentiality obligations and process your Personal Data only in accordance with our instructions.

  1. Your rights and how to complain

You have certain rights in relation to the processing of your Personal Data, including to:

  1. Right to be informed

You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.

  1. Right of access (commonly known as a “Subject Access Request”)

You have the right to receive a copy of the Personal Data we hold about you.

  1. Right to rectification

You have the right to have any incomplete or inaccurate information we hold about you corrected.

  1. Right to erasure (commonly known as the right to be forgotten)

You have the right to ask us to delete your Personal Data.

  1. Right to object to processing

You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.

  1. Right to restrict processing

You have the right to restrict our use of your Personal Data.

  1. Right to portability

You have the right to ask us to transfer your Personal Data to another party.

  1. Automated decision-making. You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.
  2. Right to withdraw consent

If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.

  1. Right to lodge a complaint

You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data.

 

How to exercise your rights

You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

 

If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated. 

  1. Children’s Privacy

We do not offer our products and services to children and we do not knowingly collect Personal Data of children without parental consent, unless permitted by law. If we learn that a child has provided us with their Personal Data we will securely and permanently delete it, in accordance with applicable law.

  1. Automated Decision-Making and Profiling

Profiling is part of what we do, as it enables us to ensure you receive surveys that are most suited to you as an individual. We don’t use automated decision-making and profiling in a way that produces legal effects, or significantly affects you. If you have any questions about this, you can contact us using the details in the ‘Contact Us’ section.

  1. Use of Cookies and Similar Technologies

Our website, survey service and app utilise cookies and similar technologies. You can find out more by viewing our cookie notice available at our website.

  1. Security and Storage of Information

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

 

If we become aware of any loss, misuse, alteration of personal data we will work closely with our IT team, Data Protection Officer and other parties as necessary to investigate the incident at hand. We have put into place the relevant procedure and policies in place to investigate, mitigate and report (when needed to relevant parties) such instances.

  1. Data Retention

We will not keep Personal Data longer than is necessary, for the purpose or purposes for which they were collected. Rolla will take all reasonable steps to destroy, or erase from its systems, all Personal Data which is no longer required. This does not apply to anonymised data.

  1. How to contact us and our Data Protection Officer

If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us at Info@ddelmar.ai.

 

  1. Changes to this privacy notice

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.

Last modified 25.11.2025.