99 Peaks - Terms & Conditions

Effective date: Dec 3rd, 2023

Last updated: June 10th, 2026

These Terms & Conditions are legally binding and govern the basis on which you (“you” or “user”) may access and use the 99 Peaks mobile and web applications, websites, web interfaces, and related services operated under the 99peaks.life domain name (collectively, the “App” or “Services”) and which are provided by 99 Peaks Pte Ltd, a Singapore company with a registered address at 8 Nassim Hill, Singapore, 258484, Singapore, with UEN 202415656Z (“99 Peaks”, “we”, “us” or “our”).

By creating an account, accessing, or using our Services, you agree to be bound by these terms and conditions (the “Agreement”) and you also acknowledge the contents of our Privacy Policy. If you do not agree to this Agreement or to the contents of the Privacy Policy, you are not authorised to use our Services and you must not use our Services.

If any of the further terms set out in the Appendices apply to you, these shall form part of this Agreement.

This Agreement and/or the Privacy Policy may be updated from time to time at our discretion, in which case your continued use of the Services following such an update will constitute your acceptance of the latest version of this Agreement and the Privacy Policy.

When using specific aspects of those Services, you may be asked to enter into further terms and conditions, either with us or with third-parties. Those terms and conditions apply in addition to this Agreement and only override the terms of this Agreement in relation to specific aspects of the Services if we have indicated this in those terms and conditions.

You acknowledge that you understand the following:

• Habit building & tracking: The Services are intended to provide suggestions to help you build healthy habits. The Services also assist you to track health marker data (e.g., blood pressure, blood markers) that you enter into the App or connect to the App from third-party devices or third-party service providers. The Services do not constitute any form of independent verification of the accuracy of such data and you are responsible for entering data accurately, using third-party devices correctly and for applying judgment on whether data obtained from third-party devices is itself accurate.
• Gamification: Users may earn virtual streaks, badges, and other progress indicators by completing required activities within the App. An auto-generated weekly recap is generated for the user at Sunday 9pm including streaks, conquered Peaks, and badges earned by users throughout the week. It also shows changes in the Peaks score and marker score. All gamification features are virtual, have no monetary value, create no vested rights, are non-transferable, and may be modified, suspended, reset, or discontinued at any time, with or without notice, at the Company’s sole discretion.
• Small Wins & Lightning: “Small Wins” are optional daily in-app activities released once per day based on the user’s local time zone. Content and availability may be modified, updated, suspended, or discontinued at any time. Completion of a Small Win may result in the award of one (1) “Lightning,” a virtual, non-transferable in-app reward with no cash value. Lightning has no monetary value and confers no entitlement to any benefit, product, service, or discount. Reward structures may be changed or discontinued at the Company’s discretion. Some content may be generated using artificial intelligence tools and may contain inaccuracies or generalized information.
• Marketplace (not currently active): The Services may also enable you to discover, book, and/or pay for third-party provided products and services (e.g., health screens via clinics, wellness-type visits like sauna or ice bath, devices such as blood pressure monitors or dynamometers, and foodstuffs or supplements) offered by third-party providers (“Third-Party Providers”). Third-Party Providers may also include clinics, wellness facilities, device vendors, and food/supplement sellers. The Marketplace is solely the venue in which you interact and contract with Third-Party Providers, and all goods and services offered, sold or contracted for by the Third-Party Providers fall outside of the scope of the Services. The Marketplace feature is not currently active. Please see section 5 for further details.
• Not medical advice or a medical device:
  • The Services are not and should not be construed by you as any kind of medical advice, diagnosis, or treatment.
  • If you have any pre-existing or suspected medical condition, it is your responsibility to seek the advice of a physician or other qualified health provider. The Services are not intended for use in the detection, diagnosis, monitoring, management, or treatment of any actual or suspected medical condition.
  • You must always use discretion (including your knowledge of any physical, mental or other health condition or health complaint that you may have such as allergens, pregnancy, injury, fatigue) before following any of the suggestions offered in the App and you must always seek the advice of a physician or other qualified health provider in relation to your use of the Services. You must call emergency services or seek urgent medical attention in the event of any actual or suspected medical emergency. The Services do not have any ability to call for or alert medical responders.
• No clinical relationship: For the avoidance of doubt, usage of the Services does not create or imply a doctor-patient, therapist-patient, or other clinical relationship with us. For instance, if any of our Third-Party Providers are medically qualified and you book services with such a provider, any such relationship is with them (only) and is also subject to the terms and conditions on which you obtain services from them. Participation in any Peaks, Small Wins, streaks, or reward systems does not guarantee specific results or outcomes. Users participate at their own discretion and responsibility.

If you are in any doubt on whether any of the Services are suitable for you, you should always consult with an appropriate medical professional and follow their directions.

No guaranteed outcomes: We cannot guarantee any health related outcome as every user is unique. Testimonials and inspirational stories that feature in the App should not be construed as any endorsement or guarantee of a particular health outcome.

Content we make available may include content of an educational, inspirational, or informational nature, including simplified explanations, summaries, anecdotes, fictional narratives, or stories based on publicly available sources.

While we aim to provide thoughtful and engaging content, we do not guarantee the accuracy, completeness, or timeliness of any content. Content may be illustrative, fictional, or generalized in nature and may not reflect the most current research or information.

You are responsible for using user discretion in relation to all content that appears as part of the Services. Whilst content may come across as being individualised, it is based on limited inputs into the App and is not a substitute for an individual consultation with a professional.

Some aspects of our content may include artificial intelligence (“AI”)-generated content, including text, audio, or video, created using AI models. AI-generated content can contain inaccuracies, omissions, or generalized statements and should not be relied upon as a sole source of truth.

Content is provided for general wellness, educational, and motivational purposes only and does not constitute any form of medical, psychological, legal, or other professional advice.

• Minimum age: You must be at least 18 years old or the age of majority in your jurisdiction, whichever is higher. If you are under the applicable age or otherwise require parental/guardian consent under local law, you are not permitted to use the Services.
• Individual users only: The Services are for individuals only. They are not intended or authorised for use by any organization without our prior written consent. You may not re-sell or re-distribute the Services for commercial gain.
• Accurate information: You agree to provide accurate, current, and complete information and to keep your account credentials secure. You are responsible for all activities under your account. You must notify us immediately of any unauthorized use of your account credentials.
• Access control: You may only access and use the Services on a device owned or controlled by you. If you access and use the Services on a device which you control but do not own (e.g. a company phone), you warrant that you have permission from the device owner to do so. You are responsible, under this Agreement, for any access and use of the Services on the device (whether or not it is owned by you).
• Technical requirements: It is your sole responsibility to ensure that your equipment (mobile device, data plan) meets all the necessary technical specifications to enable you to access and use the Services and is compatible with the Services. Where your mobile device undergoes a hardware, firmware or software update, which prevents you from being able to access the Services, we shall not have any responsibility to adapt the Services to such requirements.

The Marketplace feature is not currently active. The provisions below will apply when it becomes available.

• Third-Party Providers: As described in the Marketplace section above, the Marketplace feature lists Third-Party Providers who are solely responsible to you for their offerings, quality, regulatory compliance, pricing, availability, fulfilment, safety, fitness for purpose, quality, and customer support. User discretion is required when you select and contract with any Third-Party Provider in the Marketplace.
• Facilitation only: If we collect any payment in the App in connection with the Marketplace, we act solely as an intermediary to facilitate payment, orders or bookings with Third-Party Providers on their behalf. Any purchase you may make is a separate contract between you and the Third-Party Provider and does not constitute any of the Services.
• No endorsement: Listing in the Services does not constitute an endorsement, guarantee, or certification by us.
• Third-party terms: When you buy or book a Third-Party Provider, additional terms of that provider will apply (e.g., consent forms, clinic policies, warranty terms, cancellation/refund rules). You are responsible for reviewing and complying with those terms.
• No refunds for Marketplace transactions: All fees paid in connection with future Marketplace transactions will be non-refundable except where required by applicable law. Cancellations, changes, and refunds for Marketplace transactions are governed by the relevant Third-Party Provider’s terms and conditions. We may facilitate communications with the Third-Party Provider but we have no responsibility to provide refunds on behalf of Third-Party Providers.
• Important notices in relation to the Marketplace:
  • Health screens & wellness services: You are responsible for confirming that a particular service is appropriate for you and that you have obtained any relevant medical clearances to book such services. You should follow all pre-service instructions and disclose relevant health information to the Third-Party Provider as requested.
  • Devices, foodstuffs & supplements: For devices and consumables, follow labels and instructions, and you must check compatibility/regulatory approvals in your region, and consult a healthcare professional as relevant.

• Your content: You retain ownership of content you submit (e.g., habit entries, notes, metrics, medical reports or other health data). You grant 99 Peaks a worldwide, non-exclusive, royalty-free license to use, reproduce, and display your content solely to provide and improve the Services.
• Deidentified data: We may use deidentified or aggregated data for analytics, research, product improvement, and statistics, provided it cannot reasonably identify you.
• Complaints and Feedback: We value your feedback. Please address any complaints or feedback to us at the details below in the first instance. If you submit feedback or suggestions on how to make improvements to our Services, you also give us the right to freely adopt such improvements.

You agree not to:

• misuse the Services, interfere with its operation, or attempt to access non-public areas;
• upload unlawful, harmful, misleading, infringing, or deceptive content;
• reverse engineer, decompile, or attempt to derive source code except as permitted by law;
• use the Services to provide competing services, or for any illegal purpose;
• post medical advice or claims that could mislead others;
• circumvent fees, bookings, or payment processes.

We may suspend or terminate access for violations at our discretion.

The Services, including software, text, graphics, logos, and other materials, is owned by 99 Peaks or its licensors and protected by copyright, trademark, patent, or other proprietary rights and laws. Subject to this Agreement, we grant you a personal, limited, revocable, non-transferable, non-sublicensable license to use the Services for your personal, non-commercial purposes.

The Services may contain links to third-party sites or integrate with third-party services. We are not responsible for their content, policies, or practices, and you acknowledge that you will use such third-party sites or third-party services at your own risk and expense.

If you downloaded the App from the Apple App Store or Google Play Store, you also agree to their applicable terms and policies. Apple/Google are not responsible for providing maintenance or support for the Services and are not responsible for any claims related to the Services.

We may offer beta or experimental features that may be unstable or change without notice. We may modify or discontinue parts of the Services at any time.

To the maximum extent permitted under all applicable laws:

• THE SERVICES AND ALL CONTENT ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.
• WE DO NOT WARRANT THAT THE SERVICES WILL BE UNINTERRUPTED, SECURE, OR ERROR-FREE, OR THAT DATA WILL BE ACCURATE OR RELIABLE.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, 99 PEAKS AND ITS AFFILIATES, OFFICERS, EMPLOYEES, AGENTS, PARTNERS, LICENSORS, AND SUPPLIERS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR LOSS OF PROFITS, DATA, GOODWILL, OR OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATED TO YOUR USE OF (OR INABILITY TO USE) THE SERVICES OR THIRD-PARTY OFFERINGS.

SOME JURISDICTIONS DO NOT ALLOW CERTAIN EXCLUSIONS OR LIMITATIONS; IN THOSE CASES, THE ABOVE MAY NOT FULLY APPLY TO YOU AND YOU MAY HAVE ADDITIONAL RIGHTS.

WHERE LIABILITY CANNOT BE EXCLUDED BY LAW, OUR AGGREGATE LIABILITY SHALL BE LIMITED TO THE GREATER OF: (A) THE AMOUNTS YOU PAID TO US IN CONNECTION WITH MARKETPLACE TRANSACTIONS IN THE SIX (6) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) THE LOWEST LIABILITY LIMITATION ALLOWED BY APPLICABLE LAW.

You agree to indemnify, defend, and hold harmless 99 Peaks and its affiliates, officers, employees, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or related to your: (a) use or misuse of the Services; (b) violation of this Agreement; (c) violation of any laws or third-party rights; or (d) interactions, transactions or agreements with Third-Party Providers.

We may suspend or terminate your access at any time for actual or suspected violations of this Agreement, unlawful conduct, or risk to security or others. You may close your account at any time by contacting us at support@99peaks.life. Upon termination, your right to use the Services ceases. We may retain and use your data in accordance with our Privacy Policy and legal obligations.

• Additional Local Terms: If any of the Appendices apply to you, these will supplement this Agreement, as set out in the relevant Appendix.
• Governing law: This Agreement is governed by the laws of Singapore, excluding conflict of laws rules.
• Legal disputes: You agree to the exclusive jurisdiction and venue of the courts located in Singapore for all disputes.
• Consumer rights preserved: Where mandatory consumer laws apply, you retain any non-waivable rights in your country of residence.
• Export control and sanctions: You agree to comply with all applicable export control, sanctions, and trade laws. You are not permitted to use the Services if you are located in, or ordinarily resident in, a country or territory subject to comprehensive UN sanctions, or if you are a prohibited party under applicable sanctions laws.

By using the Services, you consent to receive communications from us electronically. We may provide notices by email, in-App messages, or by posting on our website/App. Notices are effective when sent or displayed through the App.

You may not assign or transfer the Agreement without our prior written consent. We may assign or transfer our rights and obligations in connection with a merger, acquisition, corporate reorganization, or sale of assets.

99 Peaks Pte Ltd

Address: 8 Nassim Hill, Singapore, 258484, Singapore

Support Email: support@99peaks.life

Support portal: https://99peaks.life/

This Appendix applies to users whose primary residence is in Australia or where required by Australian law.

A1. Australian Consumer Law (ACL)

Nothing in this Agreement excludes, restricts, or modifies any consumer guarantees, rights, or remedies conferred by the Competition and Consumer Act 2010 (Cth) and the Australian Consumer Law (ACL) that cannot be excluded by contract. Where goods or services are not of a kind ordinarily acquired for personal, domestic, or household use or consumption, our liability is limited, to the extent permitted by law, at our option, to:

• in the case of goods—replacement or repair of the goods, or supplying equivalent goods;
• in the case of services—resupplying the services or paying the cost of having the services supplied again.

A2. Health disclaimers and regulation

• 99 Peaks is not a medical device, is not provided by a registered health practitioner, and does not provide medical advice. For clinical matters, consult a registered health practitioner regulated under the Health Practitioner Regulation National Law.
• For devices, supplements, or therapeutic goods, always review any Therapeutic Goods Administration (TGA) listings/approvals and labeling where applicable and seek professional advice.

A3. Governing law and venue (Australia)

If you are an Australian resident, this Agreement is governed by the laws of New South Wales, Australia (unless otherwise mandatory in your state/territory), and the courts of that jurisdiction have non-exclusive jurisdiction. This clause supplements clause 16 of the Agreement and shall override clause 16 in the case of any inconsistency with its provisions.

This Appendix applies to users whose primary residence is in the United States of America (USA) or where required by any state law of the USA.

B1. No HIPAA relationship: Unless expressly agreed in a separate Business Associate Agreement (BAA), 99 Peaks is not a HIPAA covered entity or business associate in connection with your consumer use of the Services, and the Services are not intended for transmitting Protected Health Information in a HIPAA-regulated context.

B2. Consumer rights: Some states provide additional rights regarding refunds, cancellations, and notices. Those rights are preserved where mandatory.

B3. For users whose primary residence is in California:

• Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
• You agree to consciously waive all claims, both known and unknown that may be later discovered and expressly forgo and waive all protections as by California Civil Code Section 1542, which states, “[a] general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party.” By using the Services, you agree that these California Civil Code Section 1542 protections no longer apply to you.

This Appendix applies to users whose primary residence is in Singapore or where required by Singapore law. It supplements the main Agreement and, in the case of conflict specific to Singapore law, this Appendix prevails.

C1. Personal Data Protection Act 2012 (PDPA)

We collect, use, and disclose your personal data (including health data and medical reports you upload) in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”) and our Privacy Policy.

Categories of personal data we process include: account information (name, email, date of birth), health metrics (blood pressure, body weight, activity data), medical reports or health documents you upload, and device/usage data.

Health data and medical reports constitute sensitive personal data. We process such data only to provide and improve the Services as described in our Privacy Policy, and we implement appropriate technical and organisational safeguards.

We have appointed a Data Protection Officer (“DPO”). You may contact our DPO at: support@99peaks.life with the subject line “Data Protection Officer.”

C2. Overseas data transfer

Your personal data, including health data, is stored on servers located in the United States. By using the Services, you consent to this transfer. We ensure that any overseas transfer is subject to contractual protections at least equivalent to the PDPA standard, in accordance with section 26 of the PDPA and the PDPC’s Transfer Limitation Obligation requirements.

C3. Data breach notification

In the event of a notifiable data breach as defined under the PDPA, we will notify the Personal Data Protection Commission (PDPC) and, where required, affected users, within three (3) business days of assessing that the breach is notifiable.

C4. Your rights

Under the PDPA, you have the right to:

• access your personal data held by us;
• correct inaccurate or incomplete personal data;
• withdraw consent to the processing of your personal data (noting that this may affect your ability to use the Services);
• request information about the ways your personal data has been used or disclosed in the past year.

To exercise any of these rights, contact us at support@99peaks.life.

C5. Advisory on health content

The Services are not regulated as a medical device under the Health Products Act (Cap. 122D) or under guidelines issued by the Health Sciences Authority (HSA). If you are in doubt about whether any content in the Services is suitable for your health condition, consult a licensed healthcare professional.

This Appendix applies to users whose primary residence is in Malaysia or where required by Malaysian law. It supplements the main Agreement and, in the case of conflict specific to Malaysian law, this Appendix prevails.

D1. Personal Data Protection Act 2010 (PDPA Malaysia)

We process your personal data, including health data and medical reports you upload, in compliance with the Malaysian Personal Data Protection Act 2010 (“PDPA Malaysia”).

We process your personal data only for the purposes for which it was collected, as described in our Privacy Policy, and only for as long as necessary.

Health data is sensitive personal data under the PDPA Malaysia. You expressly consent to our processing of your health data and medical reports by accepting this Agreement and using the Services.

D2. Cross-border data transfer

Your personal data is stored on servers in the United States. Malaysia does not currently maintain a prescribed list of approved countries for personal data transfer under the PDPA Malaysia. By using the Services, you expressly consent to the transfer of your personal data to the United States for the purposes described in our Privacy Policy. We ensure that appropriate contractual safeguards are in place with our service providers to protect your personal data.

D3. Your rights

Under PDPA Malaysia, you have the right to:

• access your personal data held by us;
• correct inaccurate, incomplete, misleading, or not up-to-date personal data;
• withdraw consent to the processing of your personal data (noting that this may affect your ability to use the Services);
• prevent processing of your personal data for direct marketing purposes.

To exercise any of these rights, contact us at support@99peaks.life.

D4. Governing law (Malaysia)

Malaysian users retain all non-waivable rights available under Malaysian consumer protection and data protection laws, including the Consumer Protection Act 1999, notwithstanding the Singapore governing law clause in section 16 of the main Agreement.

D5. Health content advisory

The Services are not regulated as a medical device or controlled health product under Malaysian law. Nothing in the Services constitutes medical advice. Consult a registered medical practitioner for any health concerns.

This Appendix applies to users whose primary residence is in the Philippines or where required by Philippine law. It supplements the main Agreement and, in the case of conflict specific to Philippine law, this Appendix prevails.

E1. Data Privacy Act 2012 (Republic Act No. 10173)

We process your personal data, including health data and medical reports, in compliance with the Philippine Data Privacy Act 2012 (“DPA”) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (“NPC”).

Health data constitutes sensitive personal information under the DPA. We process such data solely to provide and improve the Services, under the lawful basis of your consent given at account registration and continued use of the Services.

We have designated a Privacy Officer responsible for ensuring compliance with the DPA. You may contact our Privacy Officer at: support@99peaks.life with the subject line “Privacy Officer — Philippines.”

E2. Cross-border data transfer

Your personal data, including health data, is stored on servers in the United States. We ensure that such transfer complies with Section 21 of the DPA and NPC Circular No. 16-01 by implementing appropriate contractual safeguards with our data processors. By using the Services, you consent to this transfer.

E3. Data breach notification

In the event of a personal data breach that may result in serious harm to you, we will notify the NPC and affected users within seventy-two (72) hours of discovery, in accordance with NPC Circular No. 16-03.

E4. Your rights

Under the DPA, you have the right to:

• be informed of how your personal data is processed;
• access your personal data held by us;
• object to the processing of your personal data;
• rectify inaccurate or incomplete personal data;
• erase or block personal data that is incomplete, outdated, false, unlawfully obtained, used for an unauthorised purpose, or no longer necessary;
• data portability, to receive your personal data in an electronic format;
• lodge a complaint with the NPC at complaints@privacy.gov.ph.

To exercise any of these rights, contact us at support@99peaks.life.

E5. Privacy Impact Assessment

In accordance with NPC Advisory No. 2017-03, we have conducted a Privacy Impact Assessment covering the processing of sensitive personal information (health data and medical reports) within the Services.

E6. Health content advisory

The Services are not registered as a medical device with the Philippine Food and Drug Administration (FDA). Nothing in the Services constitutes medical advice, diagnosis, or treatment. Consult a licensed physician or healthcare professional for any health concerns.