WelLink Privacy Policy

Last Updated: 4 October 2026

1. Who We Are

AL-HALLOUL RAQMIYAH Medical (One Partner) (“AL-HALLOUL”, “WelLink”, “we”, “us”, or “our”) is a company registered in the Kingdom of Saudi Arabia.

Our registered office is:

2550 Ismail Al Muzni St.
7757 Az Zahra Dist.
Jeddah, Saudi Arabia 23522

Email: Info@ddelmar.ai

For the purposes of applicable data protection legislation, including the Saudi Personal Data Protection Law (“PDPL”) and its Implementing Regulations, AL-HALLOUL acts as the Data Controller in relation to Personal Data processed through the WelLink platform, except where otherwise stated.

2. About WelLink

WelLink is a digital fitness, health and wellbeing platform that enables users to monitor, manage and better understand information relating to their activity, fitness, health and general wellbeing.

WelLink may collect information from the WelLink application, fitness or wellness bands, wearable devices, connected health devices, smartphones, third-party integrations and other supported devices and services.

Certain WelLink features may also use artificial intelligence (“AI”), machine-learning technologies and Large Language Models (“LLMs”) to analyze information and provide users with wellness-related insights, summaries and recommendations.

We are committed to protecting your privacy and processing your Personal Data in accordance with applicable laws and regulations in the Kingdom of Saudi Arabia.

3. Purpose of This Privacy Policy

This Privacy Policy explains:

• what Personal Data we collect;

• why we collect it;

• how we use and process it;

• how health and vital-sign data is processed;

• how we use AI and Large Language Models;

• when Personal Data may be shared with third parties;

• when Personal Data may be transferred outside the Kingdom of Saudi Arabia;

• how long Personal Data may be retained;

• how we protect Personal Data; and

• your rights regarding your Personal Data.

By creating an account or using WelLink, you acknowledge that your Personal Data will be processed as described in this Privacy Policy.

Where applicable law requires consent or explicit consent for a particular processing activity, we will request such consent separately.

4. Who This Privacy Policy Applies To

This Privacy Policy applies to individuals who:

1. create or use a WelLink account;

2. use the WelLink mobile application, website or related services;

3. connect a wearable, fitness band, smartwatch, medical or wellness device to WelLink;

4. participate in a WelLink wellness program, challenge, survey or service;

5. receive communications from us;

6. interact with WelLink through an employer, organization, healthcare or wellness provider, where applicable; or

7. otherwise provide Personal Data to us.

5. What Is Personal Data?

“Personal Data” means information through which an individual may be identified directly or indirectly.

This may include information such as your name, contact details, account information, identifiers, device information and other information associated with you.

Certain information is considered particularly sensitive under applicable data protection legislation.

For WelLink, this may include health information and other information concerning an individual’s physical or mental health.

We apply additional protections to Sensitive Data as required by applicable law.

6. Personal Data We May Collect

The Personal Data collected depends on the WelLink services and devices you use.

We may collect the following categories of information.

6.1 Account and Identity Information

This may include:

• full name;

• date of birth;

• age;

• gender, where provided;

• email address;

• mobile number;

• account identifiers;

• profile information;

• organization or employer information where applicable; and

• authentication and account-security information.

6.2 Physical and Profile Information

This may include:

• height;

• weight;

• body mass index (BMI);

• body composition information;

• age-related information;

• fitness information;

• wellness goals; and

• other information voluntarily entered into WelLink.

6.3 Health, Wellness and Vital Data

Depending on the devices and services connected to WelLink, we may process information including:

• heart rate;

• resting heart rate;

• heart rate variability (HRV);

• blood oxygen saturation (SpO₂);

• blood pressure;

• body temperature;

• ECG information;

• sleep information;

• stress indicators;

• fatigue indicators;

• strain indicators;

• metabolic information;

• body composition information;

• activity information;

• exercise information;

• movement information;

• steps;

• distance;

• calories burned; and

• other health, fitness, physiological or wellness measurements supported by WelLink or connected devices.

Some of this information may constitute Sensitive Data under Saudi law.

Where required by applicable law, we will obtain your explicit consent before processing Sensitive Data.

6.4 Device and Technical Information

We may collect information including:

• mobile device type;

• operating system;

• application version;

• connected wearable information;

• device identifiers;

• Bluetooth device information;

• IP address;

• log information;

• crash information;

• connection status;

• sensor information;

• application performance information; and

• information necessary to maintain device connectivity and synchronization.

6.5 Activity and Usage Information

We may collect information concerning how you interact with WelLink, including:

• features used;

• application activity;

• login activity;

• goals;

• challenges;

• workouts;

• application interactions;

• synchronization activity; and

• other service usage information.

6.6 Location Information

Where the relevant WelLink feature requires location information and you have granted the required device permissions, we may collect or process information such as:

• country;

• region;

• time zone;

• approximate location; and

• GPS location.

We will request device permissions where required.

6.7 Payment Information

If paid services are offered, payment-related information may be processed by us or our authorized payment providers.

We may not directly store complete payment-card information where payment processing is handled by an authorized third-party payment provider.

7. How We Collect Your Personal Data

We may collect Personal Data:

Directly from you

For example, when you:

• register an account;

• complete your profile;

• enter measurements;

• participate in a survey;

• contact customer support;

• configure your wellness goals; or

• provide information through WelLink.

From connected devices

Information may be collected from:

• WelLink-supported fitness and wellness bands;

• smartwatches;

• smartphones;

• fitness devices;

• health and wellness devices; and

• other supported connected devices.

From third-party services

Where you authorize an integration, WelLink may receive information from supported third-party health, fitness or wearable platforms.

The information received depends on the permissions you grant and the functionality provided by the relevant third party.

Automatically

Certain technical and usage information may be collected automatically when you use WelLink.

8. How We Use Personal Data

We may process Personal Data for purposes including:

• creating and managing your WelLink account;

• authenticating users;

• providing WelLink functionality;

• connecting and synchronizing wearable devices;

• displaying health and wellness measurements;

• monitoring fitness and activity information;

• providing wellness dashboards;

• calculating wellness metrics;

• generating trends and summaries;

• providing personalized wellness insights;

• generating alerts and notifications;

• providing customer support;

• maintaining application security;

• preventing fraud or unauthorized access;

• diagnosing technical problems;

• improving application performance;

• conducting analytics;

• improving WelLink products and services;

• complying with legal obligations; and

• providing AI-powered features as described below.

We will seek to limit processing to Personal Data that is reasonably necessary for the specified purpose.

9. Health and Sensitive Data

Health and vital-sign information processed by WelLink may constitute Sensitive Data under Saudi data protection law.

This information may include heart rate, HRV, SpO₂, blood pressure, ECG, body temperature, sleep information, body composition and other physiological or wellness measurements.

We apply additional safeguards to this information.

Where required by applicable law, we obtain your explicit consent before processing Sensitive Data.

We do not rely on legitimate interests as the legal basis for processing Sensitive Data where Saudi law prohibits doing so.

Sensitive Data will only be accessed by authorized personnel, processors and technology systems where access is reasonably necessary for the relevant processing purpose.

10. Artificial Intelligence and Large Language Models

10.1 Use of AI

WelLink may use artificial intelligence (“AI”), machine learning and Large Language Model (“LLM”) technologies to provide certain functionality.

AI may be used to:

• analyze wellness and vital-sign information;

• identify trends and patterns;

• summarize wellness information;

• explain measurements;

• generate personalized wellness insights;

• generate recommendations;

• provide conversational wellness features;

• assist users in understanding their information;

• support wellness scoring and analytics;

• improve WelLink functionality; and

• provide other AI-assisted features clearly identified within WelLink.

10.2 Information That May Be Processed by AI

Depending on the feature being used, information provided to an AI system may include selected:

• heart-rate information;

• HRV information;

• SpO₂ information;

• blood-pressure information;

• temperature information;

• sleep information;

• activity information;

• exercise information;

• steps;

• calorie information;

• stress, fatigue or strain information;

• body composition information;

• wellness history;

• age or relevant profile information; and

• other information reasonably necessary to generate the requested insight.

We seek to minimize the Personal Data transmitted to AI systems to the information reasonably required to provide the relevant feature.

Where reasonably practicable, information may be pseudonymized, de-identified, aggregated or otherwise separated from direct identifiers before being submitted to an AI provider.

10.3 Third-Party AI Providers

To provide AI-powered functionality, we may use third-party AI and cloud service providers.

These providers may include:

OpenAI, Anthropic, and other AI, machine-learning, cloud infrastructure or Large Language Model providers selected by us from time to time.

These providers may process information on our behalf to provide the requested AI functionality.

The specific provider used may change as our technology and services evolve.

We require our service providers to process Personal Data in accordance with applicable contractual, confidentiality, security and data-protection requirements.

10.4 Explicit Consent for AI Processing of Health Data

Where an AI feature requires us to disclose or otherwise process your Sensitive Data using a third-party AI service and explicit consent is required by applicable law, we will obtain your explicit consent before activating that processing.

You may withdraw your consent in accordance with applicable law.

Withdrawal of consent will not affect processing that was lawfully conducted before the withdrawal.

Certain AI-powered functionality may become unavailable if the processing necessary to provide that feature can no longer be performed.

10.5 AI Output

AI systems can produce inaccurate, incomplete or unexpected results.

AI-generated information available through WelLink is intended to provide health, fitness or wellness information and insights.

Unless a particular WelLink service expressly states otherwise, AI-generated information is not intended to constitute a medical diagnosis, medical treatment, medical advice or a substitute for consultation with a qualified healthcare professional.

Users should seek appropriate professional medical advice where they have concerns regarding their health or medical condition.

11. Automated Processing and Profiling

WelLink may use automated processing, algorithms, AI and statistical models to analyze health, fitness, activity and wellness information.

This processing may be used to:

• identify patterns;

• calculate wellness indicators;

• personalize the application experience;

• provide wellness recommendations;

• calculate fatigue, strain or similar indicators;

• generate alerts;

• provide AI-generated insights; and

• recommend relevant WelLink features.

We do not intend to use solely automated processing to make decisions that produce legal effects or similarly significant effects on you unless we have an appropriate lawful basis and implement any safeguards required by applicable law.

12. Legal Basis for Processing

We process Personal Data only where an appropriate legal basis exists under applicable Saudi law.

Depending on the circumstances, this may include:

Performance of a Contract

Processing may be necessary to provide WelLink services that you have requested, including account creation, device synchronization and application functionality.

Consent

We may request your consent for specific processing activities where consent is required or appropriate.

Explicit Consent

Where required under the PDPL and its Implementing Regulations, we will obtain explicit consent for processing Sensitive Data, including relevant health and vital-sign information.

Legal Obligations

We may process Personal Data where necessary to comply with applicable laws, regulations, court orders or lawful requirements from competent authorities.

Legitimate Interests

Where permitted under applicable law, we may process non-sensitive Personal Data where necessary to achieve a legitimate interest, provided that the processing does not prejudice your rights and interests.

We will not rely upon legitimate interests for processing Sensitive Data where prohibited under applicable Saudi law.

13. Sharing Personal Data

We do not sell your Personal Data.

We may disclose Personal Data where necessary to provide WelLink services.

Recipients may include:

• cloud hosting providers;

• database and infrastructure providers;

• analytics providers;

• notification providers;

• email and communications providers;

• security providers;

• customer-support providers;

• wearable-device integration providers;

• payment providers;

• AI and LLM providers;

• professional advisers;

• organizations providing WelLink to their users where applicable and legally permitted; and

• government or regulatory authorities where disclosure is legally required.

Third-party processors acting on our behalf are required to process Personal Data only for authorized purposes and subject to appropriate data-protection and confidentiality requirements.

14. International Transfers of Personal Data

Some of our service providers, including cloud infrastructure, analytics and AI/LLM providers, may operate infrastructure outside the Kingdom of Saudi Arabia.

As a result, Personal Data may in certain circumstances be transferred to or processed outside the Kingdom.

Any international transfer of Personal Data will be conducted in accordance with the Saudi Personal Data Protection Law, its Implementing Regulations, the Regulation on Personal Data Transfer Outside the Kingdom, and other applicable requirements.

Where required, we will implement appropriate safeguards relating to international transfers.

These safeguards may include contractual protections or other transfer mechanisms recognized by the competent Saudi authority.

We will seek to ensure that:

1. there is a valid purpose and legal basis for the transfer;

2. the Personal Data transferred is limited to what is reasonably necessary;

3. appropriate technical, organizational and contractual safeguards are implemented;

4. recipients are subject to appropriate confidentiality and data-protection obligations; and

5. required transfer risk assessments are conducted where applicable.

This section also applies where selected health or vital-sign information is processed using an AI or LLM provider whose systems or infrastructure are located outside Saudi Arabia.

15. Data Minimization

We seek to collect and process only Personal Data that is adequate and reasonably necessary for the purposes for which it is collected.

For AI-powered features in particular, we seek to limit information submitted to external AI providers to the information reasonably required to generate the requested functionality or insight.

16. Data Security

We implement appropriate technical and organizational security measures designed to protect Personal Data against:

• unauthorized access;

• unauthorized disclosure;

• accidental loss;

• misuse;

• destruction;

• alteration; and

• unauthorized processing.

Security measures may include, where appropriate:

• encryption;

• access controls;

• authentication controls;

• network-security controls;

• logging and monitoring;

• secure software-development practices;

• backup and recovery procedures;

• employee access restrictions;

• confidentiality requirements; and

• incident-response procedures.

Access to Personal Data is limited to employees, contractors, processors and other authorized parties who require access for legitimate business purposes.

17. Personal Data Breaches

If we become aware of a Personal Data breach, we will investigate and respond to the incident in accordance with our security and incident-response procedures.

Where required by applicable Saudi law, we will notify the competent authority and/or affected Data Subjects within the applicable legal requirements.

We will take reasonable measures to contain, investigate and mitigate the effects of the incident.

18. Data Retention

We retain Personal Data only for as long as necessary to achieve the purposes for which it was collected, satisfy legal or regulatory obligations, resolve disputes, maintain security and enforce applicable agreements.

Retention periods may vary depending on:

• the type of Personal Data;

• the purpose for which it was collected;

• the nature of the WelLink service;

• legal and regulatory requirements; and

• legitimate operational requirements permitted by applicable law.

When Personal Data is no longer required, we will take appropriate measures to securely delete, destroy or anonymize it in accordance with applicable law.

Anonymized information that can no longer reasonably identify an individual may be retained for analytics, research, statistical or service-improvement purposes where legally permitted.

19. Your Rights

Subject to the Saudi Personal Data Protection Law and other applicable legislation, you may have rights regarding your Personal Data.

These may include:

Right to Be Informed

You have the right to receive information about how we collect, use, store and process your Personal Data.

Right of Access

You may request access to your Personal Data in accordance with applicable law.

Right to Obtain a Copy

Where applicable, you may request a copy of Personal Data held about you in a clear and readable format.

Right to Correction

You may request correction, completion or updating of Personal Data that is inaccurate, incomplete or outdated.

Right to Request Destruction

You may request destruction of your Personal Data where the applicable legal conditions are satisfied.

Certain information may need to be retained where retention is required or permitted by law.

Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent.

Withdrawal does not affect the lawfulness of processing conducted before consent was withdrawn.

Rights Relating to AI and Sensitive Data

Where AI-powered processing of Sensitive Data is based upon your explicit consent, you may withdraw that consent.

Doing so may prevent us from providing the affected AI-powered feature.

20. Exercising Your Rights

To exercise your privacy rights or submit a privacy-related request, contact:

AL-HALLOUL RAQMIYAH Medical (One Partner)
Email: Info@ddelmar.ai

We may need to verify your identity before processing a request to protect your information against unauthorized disclosure.

Requests will be processed in accordance with the timeframes and requirements established under applicable Saudi law.

21. Children’s Privacy

WelLink is not intended to collect Personal Data from children except where the service is specifically designed to permit such use and appropriate consent or authorization has been obtained in accordance with applicable law.

Where parental or guardian consent is legally required, we will take reasonable measures to obtain such consent before processing the child’s Personal Data.

If we become aware that Personal Data relating to a child has been collected contrary to applicable legal requirements, we will take appropriate steps to delete or otherwise lawfully handle that information.

22. Cookies and Similar Technologies

Our website and application may use cookies, SDKs and similar technologies to:

• operate WelLink;

• maintain user sessions;

• remember preferences;

• understand application performance;

• identify technical problems;

• maintain security; and

• perform analytics.

Where required, we will provide appropriate notices or obtain consent for the use of such technologies.

23. Third-Party Services and Integrations

WelLink may allow users to connect third-party devices, wearable platforms, applications or services.

When you connect such a service, information may be exchanged between WelLink and the relevant third party according to the permissions you provide.

Third-party services may operate under their own privacy policies and terms.

We recommend reviewing the privacy policies of any third-party service you choose to connect to WelLink.

24. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes to WelLink;

• new functionality;

• new AI or technology providers;

• changes to our processing activities;

• changes to applicable laws or regulations; or

• changes to our security or privacy practices.

Where required by applicable law, we will notify you of material changes and obtain new consent where the change requires consent.

The effective date shown at the beginning of this Privacy Policy identifies the latest version.

25. Complaints

If you have concerns regarding how your Personal Data is processed, please contact us first at:

Info@ddelmar.ai

You may also have the right to submit a complaint to the competent data-protection authority in the Kingdom of Saudi Arabia in accordance with the Saudi Personal Data Protection Law and its Implementing Regulations.

26. Contact Us

For questions about this Privacy Policy, our privacy practices, the processing of health information, AI processing, or to exercise your Personal Data rights, please contact:

AL-HALLOUL RAQMIYAH Medical (One Partner)

2550 Ismail Al Muzni St.
7757 Az Zahra Dist.
Jeddah, Saudi Arabia 23522

Email: Info@ddelmar.ai

Last Updated: 4 October 2026