Effective date: October 4, 2026

1. Introduction and Scope

Unprude ("we", "our", or "us") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and protect the personal data of users ("you") of the Unprude mobile application, the Unna by Unprude AI chat feature, our sexual health services listings, teleconsultations, and our websites (collectively, the "Services").

Two data protection frameworks apply to us. The Singapore Personal Data Protection Act 2012 governs the Services operated by our Singapore entity: the Unprude app, Unna, our websites, and all transactions with users outside the Philippines. The Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission govern the Services operated by our Philippine entities: product retail, teleconsultations, education programming, and our sexual health services listings. Philippine law applies in addition wherever we process the personal data of people in the Philippines or process it through our staff there. Section 2 explains which entity is responsible for what, and we apply the higher of the two standards across all of them.

We offer our Services in the Philippines and Singapore, and Section 16 sets out your rights under each of those laws. The app can be downloaded elsewhere, and Section 16.3 explains how we handle your data if you use it from outside those two countries.

Where we process information about your sexual health, we do so only with your specific and express consent, obtained separately from your general acceptance of this policy. Section 10 explains the additional protections that apply to HIV and sexual health testing.

2. Who We Are and Who Is Responsible

Different parts of the Unprude group are responsible for different Services:

• Unprude Pte. Ltd., incorporated in Singapore, is the controller for the Unprude mobile application, the Unna by Unprude AI chat feature, and our websites. It is also the controller for all transactions with users outside the Philippines. It is the responsible organisation under the Singapore PDPA.
• Intimate Wellness Corporation, incorporated in the Philippines, is the controller for Unprude Play product orders placed from within the Philippines — personal care products, gels, and toys. It is a personal information controller under the Philippine Data Privacy Act. It does not handle sexual health service bookings, teleconsultations, or any clinical information.
• Unprude Center for Sexology, Inc., a Philippine non-profit corporation, is the controller for teleconsultations delivered by our licensed clinicians, and counselors, for our aggregated sexual health services listings, and for its certification and education programming. It is a personal information controller under the Philippine Data Privacy Act.

Unprude Pte. Ltd. also provides the shared platform the group runs on — the app, booking and scheduling systems, payment handling, and back-office support. Where it does this for our Philippine entities, it acts as a personal information processor on their instructions under a written outsourcing agreement, not as a controller in its own right. It may not use data it handles in that role for its own purposes.

Which entity is responsible depends on both the Service you are using and where you are. If you are outside the Philippines, your transactions are with Unprude Pte. Ltd. in Singapore. If you are in the Philippines, your product orders are with Intimate Wellness Corporation, and your teleconsultations and sexual health service bookings are with Unprude Center for Sexology, Inc.

Where you use both — for example, browsing content in the app and then placing an order — the two entities share the personal data needed to give you a single, working experience, under a written agreement between them. Each remains responsible for the Services it controls.

You do not need to work out which entity holds your data. Contact us at help@unprude.com about anything in this policy and we will handle your request across the group.

Our Data Protection Officer is registered with the National Privacy Commission and can be reached at help@unprude.com. Full contact details are in Section 21.

3. What Personal Data We Collect

Account and identity data

• Name
• Email address
• Date of birth or age
• Gender
• Persona name and persona description

Health and wellness information you provide

• Responses to in-app questionnaires, quizzes, and exercises
• Relationship status and life phase
• Sexual health-related information you voluntarily provide
• Messages, context, and profile attributes shared during interactions with Unna

Order and delivery data

• Delivery address
• Phone number
• Order contents, order reference, and order history
• A record of which partner clinic fulfilled each order

Usage and technical data

• App usage and activity data, including learning progress
• Device and technical data such as IP address, device type, and operating system

We do not collect or store full payment card details. Teleconsultations and other services are paid through Stripe, and app purchases such as Unna credits through Apple In-App Purchase (and Google Play where offered), each subject to its own privacy policy. From card payments we keep only the card brand, the last 4 digits, and the receipt.

Information about your health and your sex life is sensitive personal information under the Philippine Data Privacy Act, and it is protected as sensitive data under the Singapore PDPA. Under Philippine law we may process it only on the narrow grounds the Act allows — in our case, your specific and express consent. We apply stricter access controls to it and disclose it only as described in this policy.

4. Purpose of Collection and Use

We collect and use your personal data for the following purposes:

• To create and manage your account
• To deliver and personalise app content, features, and AI chat responses
• To track and display your learning progress
• To process purchases and manage subscriptions
• To pass your bookings and orders to the partner clinic, provider or logistics provider delivering them
• To respond to your enquiries and provide customer support
• To improve our Services through analysis of usage patterns
• To maintain the security of our Services and prevent fraud and abuse
• To send you service-related communications, including order and delivery updates
• To send you marketing messages from the Unprude Ecosystem, including but not limited to Unprude Play, Unna by Unprude, and Unprude Center for Sexology, Inc.
• To comply with our legal, regulatory, tax, and record-keeping obligations

We do not use your health information, your Unna conversations, or your order history for advertising or marketing targeting, and we do not sell any of it.

You may withdraw consent for marketing communications at any time by using the unsubscribe option in our emails or by adjusting your preferences in the app. Withdrawing marketing consent does not stop service-related messages such as order and delivery updates.

5. Legal Bases and Consent

Under the Philippine Data Privacy Act we process ordinary personal information on the basis of your consent, the performance of our contract with you, our compliance with a legal obligation, or our legitimate interests where these are not overridden by your rights. Where we rely on legitimate interests, we carry out and document an assessment as required by National Privacy Commission Circular No. 2023-07.

Sensitive personal information — including everything concerning your health and sex life — is processed only with your consent, given specifically and expressly, in writing or electronically, before we process it and for the purpose we have told you about. We ask for this consent separately from your general acceptance of this policy.

Under the Singapore PDPA we collect, use, and disclose personal data with your consent, or where the Act permits us to do so without consent — for example, to conclude or perform a transaction you have requested, or to comply with a legal requirement.

You may withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing carried out before you withdrew it, and it may mean we can no longer provide certain features, such as Unna or our partner provider listings.

6. Disclosure of Personal Data

We do not sell your personal data to third parties. We may share your data with:

• Partner clinics and service providers. When you book or order a sexual health service, we share limited contact and delivery details with the provider you selected. See Section 8.
• Other Unprude group entities, as described in Section 2 — for example, where you order a product through the app and Intimate Wellness Corporation needs your delivery details to ship it, or where Unprude Pte. Ltd. processes data on a Philippine entity's instructions as its platform provider.
• Unprude Center for Sexology, Inc., which delivers teleconsultations as described in Sections 8 and 9, and which we may contact you on behalf of where you have consented to receive its programming and marketing communications.
• Service providers who support our operations, including cloud infrastructure, analytics, AI processing tools, customer support platforms, and payment processors, under written outsourcing or data processing agreements that limit their use of your data to providing services to us.
• Logistics and delivery providers, where a courier needs your delivery details to complete a shipment.
• Regulatory or legal authorities, where required by law or a valid legal process, or where we reasonably believe disclosure is necessary to comply with a legal obligation or to prevent serious harm.
• Professional advisers such as lawyers, auditors, and insurers, where necessary and subject to duties of confidentiality.
• Successor entities in the event of a merger, acquisition, or sale of business assets, in which case you will be notified.

Service providers are personal information processors: they handle your data on our behalf and under our instructions. Partner clinics are different — they act as independent controllers of the information we share with them, as explained in Section 8.

7. Unna by Unprude AI Chat

To provide you with relevant and personalised guidance, our Services include an AI-powered chat feature called Unna by Unprude. To process your queries and generate context-aware responses, the following data is shared with our AI providers: Dify, which hosts Unna and stores your conversation history so that Unna can continue a conversation, and OpenAI, which generates the responses (and, for voice features where offered, ElevenLabs):

• User identity and persona: first name, gender, date of birth, persona name, and persona description.
• Quiz answers: your relationship status, life phase, and any Unna-specific answers you have provided.
• Chat context: the message you have just sent, together with previous messages in the chat retrieved from our vector database.
• Curated knowledge base: relevant content retrieved from our vector database using semantic search based on your message. This includes curated information about sexual health, relationships, products, services, clinics, and hotlines, so that Unna can provide safe and accurate recommendations.

Your Unna conversations are not shared with partner clinics, advertisers, or other users. Our AI providers act as our processors under written agreements that place explicit limits on what they may do with your data. Under those agreements they may not use your conversations to train, fine-tune, or otherwise improve their own models, and they may not use your data for any purpose other than providing Unna to you. Dify stores your conversation history on our behalf until your account is deleted, when we delete it. OpenAI may retain your messages only transiently, for short-term operational and abuse-monitoring purposes, after which they are deleted from its systems. We do not permit open-ended vendor-side retention of your conversations, and we review these terms whenever we change or add a provider.

8. Sexual Health Services from Partner Providers

Unprude aggregates sexual health services — testing, screening, consultations and related products — offered by independent clinics and service providers. We list what they offer, let you compare and choose, and pass your booking or order to the provider you select. We do not deliver these services ourselves. The provider does, and it is responsible for the service it gives you.

You will find these listings across our website and app, including on the page titled "Get Checked". This service is operated using the platform Unprude Pte. Ltd.

What we share, and when

Nothing is shared with any provider while you are browsing. When you book or order, we share the following with the provider you have chosen, and with no other provider:

• Your name
• Your email address
• Your phone number
• Your delivery address
• The item or items you ordered, and your order reference

We share this only after you confirm a booking or order, and only with the provider delivering it. We do not share your Unna chat history, quiz responses, learning progress, in-app activity, or any other health information you have given us.

Because booking a sexual health service can itself reveal information about your health, we ask for your separate, express written consent to this sharing at the point of booking, in addition to your consent to our collection of the information. You can withdraw that consent at any time, though we cannot recall information already sent to a provider.

Providers act as independent controllers and contractors

Once we pass your details to a provider, that provider handles the information under its own privacy policy and is separately responsible for it as a personal information controller in its own right. Its policy governs how it collects, uses, stores, retains, and discloses that information, including anything it sends you about your booking, your results, or follow-up care. We identify the provider before you confirm, and either link its privacy policy or tell you how to get it.

Test results

Where the service involves testing, the provider — not Unprude — performs the test and delivers your results directly to you. We do not receive, store, or have access to your test results.

Your choices

You can browse and compare providers without booking, and nothing is shared until you confirm. If you have booked and wish to have your data corrected or deleted, contact us at help@unprude.com. Because the provider holds that information in its own systems, you will also need to contact it directly for any data it holds. We will tell you who that is and how to reach them.

9. Teleconsultations

Teleconsultations are delivered by independent contractors. When you book one, Unprude Center for Sexology, Inc. is the personal information controller for your consultation and the treating clinician holds your clinical record. Teleconsultations are booked and delivered on a platform provided by Unprude Pte. Ltd., and your payment is processed through it, but this does not change who controls your clinical information: responsibility follows who decides how the consultation is delivered, not who runs the software or handles the payment.

What we collect

• Booking and scheduling details
• The reason for your consultation and the history you give your clinician
• Clinical notes, assessments, and any recommendations or referrals made
• A recording of the consultation only where you have separately agreed to one. Consultations are not recorded by default

Our basis for processing

Clinical information is sensitive personal information. We process it with your consent and, under the Data Privacy Act, because processing is necessary for medical treatment carried out by a qualified health professional and an institution bound by professional confidentiality. Your clinician is separately bound by the confidentiality obligations of the Medical Act and the Professional Regulation Commission's rules of ethics, which apply independently of this policy.

Who can see your consultation

Your clinical record is accessible only to your treating clinician and the small number of Center personnel who need it for scheduling, follow-up, and record-keeping. We do not share it with Intimate Wellness Corporation or with partner clinics. It is never used for marketing, never used to train or improve Unna, and never sold.

Because the consultation runs on Unprude Pte. Ltd.'s platform, that company hosts and maintains the systems your record sits in. It does so strictly as a processor on the Center's instructions, under a written agreement that bars it from using your information for its own purposes, and access to clinical content is technically restricted to your clinician and authorised Center personnel.

Your consultation records and your service booking records are kept separately, and we do not combine them or use one to inform the other unless you ask us to — for example, where you want your clinician to see a result.

Billing

Your payment is handled through the platform, so Unprude Pte. Ltd. processes your name, contact details, the fee charged, and the transaction reference for that purpose and for our accounting records. It does not receive the reason for your consultation, your clinical notes, or anything else said during it.

Referrals

If your clinician refers you for testing or to another provider, we share only what that provider needs, and we tell you before we do it.

Records and retention

Clinical records are kept for the period required by the professional and regulatory record-keeping obligations that apply to your clinician. This is longer than the 24-hour account deletion period described in Section 14, and deleting your Unprude account does not delete your clinical record. Payment, consultation and Unna credit records — are kept for as long as the law requires, and are no longer used for anything else.

10. HIV and Sexual Health Testing Confidentiality

If a service you book through us involves HIV testing, or HIV is discussed in a teleconsultation, additional protections apply under the Philippine HIV and AIDS Policy Act (Republic Act No. 11166). These obligations bind Unprude Pte. Ltd. for any booking made from outside the Philippines, the provider or clinician delivering the service, and our personnel individually. Information that you have undergone an HIV-related test, have been exposed to HIV, or have HIV or an HIV-related illness is confidential, and it is unlawful to disclose it without your written consent, except in the narrow circumstances the Act permits.

Accordingly:

• We keep records relating to HIV and sexual health testing separate from your other account records, with access restricted to the smallest number of authorised personnel necessary.
• We disclose your booking information only to the provider delivering the service to you, and only with your written consent given at checkout.
• We do not disclose HIV-related information to your employer, school, insurer, family, or partners, and we will not do so at their request.
• Testing arranged through Unprude is voluntary. Your results are delivered to you by the clinic, with counselling, and are never published or shared by and with us.
• Our personnel are bound by these confidentiality obligations, and unauthorised disclosure is a criminal offence for which individuals as well as the organisation may be liable.

These protections apply in addition to, and do not reduce, your rights under the Data Privacy Act.

11. International Data Transfers

App and website data, and data from transactions outside the Philippines, is controlled by Unprude Pte. Ltd. in Singapore. Philippine product orders are controlled by Intimate Wellness Corporation. Both are stored on cloud infrastructure that may be located in either country or elsewhere in the region, our operations staff are based primarily in the Philippines, and our service providers operate in a number of countries. Your data will therefore be transferred to, stored in, and processed in countries other than the one you live in, and those countries may have data protection laws that differ from your own.

Whenever we transfer your data across borders, we take steps to ensure it receives a comparable standard of protection:

• From the Philippines. Intimate Wellness Corporation and Unprude Center for Sexology, Inc. remain accountable for personal data transferred abroad and use contractual measures consistent with the Data Privacy Act and National Privacy Commission guidance. Clinical records from teleconsultations, and service booking records, are stored in Singapore on our hosted infrastructure, with access restricted as described in Section 9.
• From Singapore. Unprude Pte. Ltd. ensures recipients are bound by legally enforceable obligations to provide a standard of protection comparable to that required under the PDPA.
• Between our entities. Transfers between our entities are governed by written intra-group agreements applying the protections in this policy to each of them.
• To our service providers. We contractually require providers outside the Philippines and Singapore to protect your data to the standards described in this policy, and we assess their security practices before engaging them.

You may request a copy of the safeguards we use by contacting us at help@unprude.com.

12. Storage and Security

Your personal data is stored on cloud infrastructure provided by Amazon Web Services (AWS) in Singapore, through our database provider Supabase and our AI conversation provider Dify, which maintain independently audited security certifications including SOC 2 Type 2.

We implement the organisational, physical, and technical security measures required by the Philippine Data Privacy Act and its Implementing Rules and by the Singapore Personal Data Protection Act, aligned with recognised international baselines including ISO/IEC 27001 for information security management and ISO/IEC 27701 for privacy information management. These measures include:

• Encryption of personal data in transit using current TLS standards, and encryption at rest
• Access controls and role-based restrictions on staff access, with additional restrictions on sensitive personal information such as clinical records and service booking data
• Written confidentiality undertakings from our personnel
• Security due diligence on vendors before engagement, and written processing terms with each of them
• Logging and review of access to sensitive personal information
• Regular review and testing of our security posture, and periodic staff training

Together these are intended to safeguard your data against unauthorised access, disclosure, alteration, or destruction.

Usage data may be anonymised for analytics and product development. Anonymised data does not identify any individual and, once anonymised, falls outside the scope of most data protection laws.

No system is completely secure. While we work hard to protect your data, we cannot guarantee absolute security, and you share information with us at your own discretion.

13. Data Breach Notification

We maintain procedures to detect, assess, and respond to security incidents and personal data breaches, and we keep the records the law requires.

Philippines. Where a breach involves sensitive personal information or information that may enable identity fraud, and there is a real risk of serious harm to you, we will notify the National Privacy Commission and the affected individuals within 72 hours of knowledge of the breach, as the Data Privacy Act requires.

Singapore. Where a breach is likely to result in significant harm to affected individuals, or is of a significant scale, we will notify the Personal Data Protection Commission as soon as practicable, and in any case no later than 3 calendar days after we determine that the breach is notifiable. We will notify affected individuals at the same time, unless an exception under the PDPA applies.

Where a single incident engages both regimes, we apply the earlier deadline.

14. Retention of Personal Data

We retain your personal data for as long as is necessary to fulfil the purposes for which it was collected. When you ask us to delete your account, we email you a link to keep it, and deletion completes within 24 hours of your request, except where we are required to retain certain records — for example, order and transaction records kept for the period required by applicable tax and accounting law.

Data already shared with a partner clinic is retained by that clinic according to its own retention policy and any clinical record-keeping obligations that apply to it. Deleting your Unprude account does not delete records held by a clinic.

Anonymised data may be retained indefinitely for research and product improvement purposes.

15. Your Privacy Rights

Wherever you live, you can ask us to:

• Tell you whether we hold personal data about you, give you access to it, and explain how we use it
• Correct any inaccurate or incomplete personal data
• Delete or block your personal data, subject to any legal or contractual obligations we may have to retain it
• Withdraw consent for the collection, use, or disclosure of your data at any time
• Object to our processing of your data
• Identify the partner clinics or other third parties to which your personal data has been disclosed
• Give you a copy of your data in a portable, commonly used electronic format

To exercise any of these rights, contact us using the details in Section 21. We will respond within 30 days, or sooner where the applicable law requires it. We will not discriminate against you for exercising your rights: we will not deny you Services, charge you a different price, or provide a lower quality of service.

We may need to verify your identity before acting on a request. If we decline a request, we will tell you why, and you may appeal our decision by replying to our response. We will inform you of the outcome of your appeal within 45 days, along with details of how to contact the relevant regulator if you remain dissatisfied.

16. Your Rights by Location

The following applies in addition to the rest of this policy.

16.1 Philippines

The Data Privacy Act of 2012 applies to Intimate Wellness Corporation as controller of Philippine product orders, to Unprude Center for Sexology, Inc. as controller of teleconsultations and our sexual health services listings, and to processing carried out by our personnel in the Philippines. It gives you the rights to be informed, to object, to access, to rectification, to erasure or blocking, to damages, and to data portability, together with the right to lodge a complaint with the National Privacy Commission.

Information about your health and sex life is sensitive personal information. We process it only with your consent, given specifically and expressly before processing, or where the Act otherwise permits — for example, where processing is necessary to protect your life and health and you are unable to give consent, or where it is required for medical treatment by a qualified practitioner or institution bound by confidentiality.

Our Data Protection Officer is registered with the National Privacy Commission, and our data processing systems are registered where registration is required. You may contact our DPO at help@unprude.com. If you are not satisfied with our response, you may file a complaint with the National Privacy Commission.

Additional confidentiality protections apply to HIV-related information under Republic Act No. 11166. See Section 10.

16.2 Singapore

The PDPA applies to Unprude Pte. Ltd. as controller of the app, Unna, our websites, and transactions placed from outside the Philippines. You have the rights described in Section 15, including access, correction, and withdrawal of consent on reasonable notice. If you are dissatisfied with our handling of your personal data, you may lodge a complaint with the Personal Data Protection Commission of Singapore.

16.3 Users outside the Philippines and Singapore

We offer and market our Services in the Philippines and Singapore. We do not direct them at, advertise them in, or tailor them for users in other countries: we do not price in other currencies, we do not translate the app into other languages, and we do not run marketing campaigns aimed at people outside these two countries.

The Unprude app can nevertheless be downloaded anywhere the app stores make it available. If you use it from another country, your personal data is processed in the Philippines and Singapore under the standards set out in this policy, which we apply as our global minimum. Some Services are limited by where you are — teleconsultations and partner provider services are delivered by clinicians, clinics and providers in the Philippines, and product delivery depends on where we ship.

If the law where you live gives you privacy rights beyond those in Section 15, contact us at help@unprude.com and we will honour them to the extent that law requires. If we begin offering or marketing our Services in another region, we will update this policy and tell you before we do.

17. Automated Decision-Making and AI

Unna generates its responses using artificial intelligence, and we use automated systems to personalise content and recommendations in the app. These systems do not make decisions that produce legal effects concerning you or that otherwise significantly affect you. We do not use automated processing to determine eligibility for products, pricing, credit, insurance, employment, or healthcare. Where our data processing systems involve automated decision-making or profiling, we register them with the National Privacy Commission as required.

Unna provides sexual health education and general guidance. It does not diagnose, treat, or prescribe, it is not a substitute for care from a licensed clinician, and using it does not create a clinician-patient relationship. A teleconsultation is different: it is care delivered by a licensed clinician, it does create a clinician-patient relationship, and it is governed by Section 9. If you would like a human to review anything Unna has told you, contact us at help@unprude.com.

18. Age Restriction

Our Services are intended for adults. You must be at least 18 years old to create an account, use Unna, or book a service through Unprude. We do not knowingly collect personal data from anyone under 18 through these Services. If we become aware that we have collected personal data from a person under 18 without appropriate consent, we will delete it promptly. If you believe a minor has provided us with personal data, please contact us at help@unprude.com.

19. Biometric Data

The Unprude app offers optional biometric login using fingerprint or facial recognition. Biometric authentication is managed entirely by your device's operating system. Unprude does not access, collect, transmit, or store any biometric data. All biometric data remains solely on your device at all times.

20. Cookies and Tracking

Our websites may use cookies and similar tracking technologies to keep you signed in, remember your preferences, improve your browsing experience, and analyse site traffic. Where required by law, we ask for your consent before setting non-essential cookies and give you a way to change your choice at any time. You may also control cookie preferences through your browser settings. Disabling cookies may affect certain features of the website.

21. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a complaint about how we handle your personal data, please contact our Data Protection Officer at:

Data Protection Officer, Unprude
help@unprude.com

Unprude Pte. Ltd.
33A Pagoda St, Singapore

Intimate Wellness Corporation
3rd Floor 2272 Chino Roces, Makati City, Philippines

Unprude Center for Sexology, Inc.
Tower C The Grove by Rockwell, Brgy Ugong, Pasig City, Philippines

A request sent to any of these entities, or to the address above, reaches all three.

We take all privacy concerns seriously and will respond promptly. If you are not satisfied with our response, you may lodge a complaint with the National Privacy Commission of the Philippines or the Personal Data Protection Commission of Singapore.

22. Changes to This Policy

We may update this Privacy Policy from time to time. Any material changes will be communicated to you via the app or by email, and where the law requires it we will ask for your consent again. Continued use of our Services after any changes constitutes your acceptance of the updated policy. The current version will always be available at unprude.com/pages/privacy-policy.

This Privacy Policy was prepared with reference to the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, the Philippine HIV and AIDS Policy Act, professional confidentiality obligations applicable to licensed clinicians, and the Singapore Personal Data Protection Act 2012.