Town Health International Medical Group Limited and its subsidiaries, affiliates and related companies (together the “Group”) (and also referred to as "we", "us", “our” for the purposes of this Privacy Policy Statement as appropriate) recognise our responsibilities under the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (“PDPO”) and are committed to protecting the privacy, confidentiality and security of the personal data collected by us.
In relation to any personal data supplied to us through our website, mobile application or otherwise, continued use by you of our website or mobile application or your continued relationship with us shall be deemed to be your acceptance of and consent to this Privacy Policy Statement, as amended from time to time.
Please note that if you do not provide us with certain categories of personal data which are specified to be mandatory at the time of collection, we may not be able to provide the information, products or services you have asked for or process your requests, applications or registrations (as the case may be).
If you have any questions about this Privacy Policy Statement or how we use your personal data, please contact us through one of the communication channels set out below.
Purpose
We may collect your personal data including but not limited to your name, mailing address, telephone number, email address and date of birth, which may be used and retained by us for the following purposes:
- processing your application and registration for our services;
- providing you with our services and administering your account in relation to such services;
- handling and following up enquiries, complaints or feedback;
- managing, operating, maintaining and improving our services provided to you;
- marketing of our products and/or services;
- conducting research and statistical analysis in order to improve our services and for marketing and promotional purposes;
- prevention and/or detection of crime;
- meeting the requirements of any governmental, legal or regulatory authority in Hong Kong under the requirements of any law binding on us; and
- other purposes directly relating or incidental to any of the above.
Direct Marketing
We intend to use your personal data (including your name, mobile phone number, email address and other information) for direct marketing to you (by email, phone, SMS or the like) in relation to offers and promotions from us for health and beauty related products and services. We will not use your personal data for direct marketing unless you have given your consent (which may include an indication of no objection) and have not subsequently opted out.
Where your personal data is used for direct marketing, it may be passed by us to third party service providers who are under contractual obligations to protect your personal data against unauthorized or accidental access, process, erasure and use.
Other Transfers of Your Personal Data
We may disclose and transfer (whether in Hong Kong or abroad) your personal data to the following parties:
- any contractor, agent or service provider which provides administrative, data processing, research and marketing, financial, information technologies, telecommunications, payment, delivery, professional, after-sale or other services to us, in connection with the purposes specified under the paragraph headed “Purpose” above;
- our service partners to facilitate our services to you;
- any members of the Group and made available to appropriate persons in the Group;
- any third party service providers if you opt to use or receive services from them;
- any governmental, legal or regulatory authority to which we have a legal duty to provide such data;
- any actual or proposed assignee, transferee or successor of or to our rights in respect of your personal data in connection with a merger, sale or transfer (whether assets or shares); and
- other parties as notified to you at the time of collection of personal data.
We may share aggregate data (which does not allow you to be identified personally) with third parties for various purposes (including marketing and advertising), and may use such data in order to better understand your needs and to improve and adapt our products and services.
It may be necessary and/or prudent for us to transfer certain personal data and/or data to members of the Group or service providers outside of Hong Kong. This may occur if our servers, suppliers and/or service providers are based overseas or if you use our services while you are overseas. We will take steps to ensure that your personal data and/or data is used by such overseas third parties in accordance with this Privacy Policy Statement and that such overseas third parties observe strict confidentiality and data protection obligations.
Data Security
We will take all practicable steps to ensure the security of your personal data held by us and to avoid unauthorised or accidental access, erasure or other use, and that the personal data may only be accessed by authorised personnel.
You should be aware that no system is impenetrable and no information provided over the internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the internet. To the extent permitted by the law, we shall not be liable for any security breach or inadvertent loss or disclosure of personal data transmitted to our website and/or mobile application.
Data Retention
Your personal data will be retained for as long as reasonably required to fulfil the purpose(s) of collection, after which your personal data will then be destroyed unless retention is required to satisfy any legal, regulatory or accounting requirements or to protect our interests.
Use of Cookies
We use cookies on our website and mobile application. Cookies are data files which are stored on your device to ensure the functioning of websites and mobile applications. These data files will document your visit to a website or a mobile application and allow tracking and implementation of your preferences and settings. This information collected from you through the use of cookies are used to compile general statistics in relation to how often certain areas of the website or mobile application are visited such that the website or mobile application may be tailored to be more useful and user-friendly. No personal data will be collected unless you explicitly provide that information to us. You may refuse to accept cookies on your device by modifying the settings on your device. However, if you do so, you may be unable to use certain functions or features of our website or mobile application.
Third Party Merchants
We may have online stores or service providers hosted on our website/mobile application which are operated by third party merchants. If you want to use, order or receive any services and/or products from any of them, please note that any personal data you provide, once transferred to the relevant merchant, is beyond our control and thus outside the scope of protection afforded by us.
Links to Third Party Websites
This Privacy Policy Statement applies to our website and mobile application. Our website/mobile application may contain links to other third party websites which may collect your personal data. The collection and use of personal data by these other third party websites are beyond our control and are subject to the privacy policies of the relevant third party website. We shall not be responsible for any privacy policies of those third party websites.
Children
We do not knowingly accept information from children under the age of 13 and they shall not submit any personal data to us without the consent of his parent or guardian. However, this Privacy Policy Statement applies to all users of our website/mobile application even though we are unable to distinguish the age of users of our website/mobile application. If a child has provided us with personal data without the consent of his parent or guardian, the parent or guardian should contact us to request for the removal of the information.
Personal Data Access and Correction
Under the PDPO, you have the right to:
- check whether we hold any of your personal data;
- access to your personal data held by us;
- ascertain the types of personal data held by us;
- request us to correct any personal data which is inaccurate;
- ascertain our policies and practices (from time to time) in relation to personal data; and
- opt out from receiving direct marketing materials from us at any time.
All requests for data access or correction shall be made in writing (sent by post or email) and addressed to:
By Post:
Town Health International Medical Group Limited
6/F, Town Health Technology Centre
10-12 Yuen Shun Circuit
Siu Lek Yuen, Shatin
New Territories, Hong Kong
By Email:
enquiry@townhealth.com
We may ask you to provide certain details about yourself so that we can ascertain you are the person to whom the personal data refers.
We are entitled to charge a reasonable fee for the processing of any data access or correction request.
Variation of Privacy Policy Statement
We reserve the right to amend or update this Privacy Policy Statement from time to time at our sole discretion.
General
In the event of any inconsistency or discrepancy between the English and Chinese versions of this Privacy Policy Statement, the English version shall prevail.
February 2022