Personal data relating to you held or collected by the Company may be used by the Company for the following purposes (“Purposes”):

(i) providing the Products and Services;

(ii) enhancing care coordination across the Company and its direct and indirect parent, subsidiaries and affiliates (the “Group” and individually referred to as “Group Entity”) and/or our partner healthcare providers for better outcome;

(iii) roviding personalised medical information, health information, information of our Products and Services,

(iv) processing billing and payments, insurance claims, and/or collecting amounts due from you;

(v) processing your request for registration as a user of the Company’s application, portal and/or website(s) and administering your user account;

(vi) verifying your identity before providing the Products and Services;

(vii) operating, maintaining, evaluating, improving troubleshooting problems, and understanding your preference(s) with the Company’s application, portal and/or website(s);

(viii) improving the experience of the Company’s application, portal and website(s) and ensuring the data collection purposes can be fulfilled by collecting information through cookies and other tracking technologies;

(ix) promotional or marketing purposes;

(x) performing statistical or other research and data analysis related to the provision of the Products and Services;

(xi) exercising the Company’s rights in connection with the provision of the Products and Services to you from time to time;

(xii) performing evaluation, planning and designing of the Products and Services with a view to improving or enhancing the Products and Services;

(xiii) communicating with you or your authorized representative(s);

(xiv) performing investigations and processing of complaints and disputes;

(xv) meeting any disclosure requirements imposed by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations binding on or applying to the Company or the Group or with which the Company or the Group is expected to comply;

(xvi) complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information applicable to us or the Group and/or any other use of data and information in accordance with any applicable programs for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;

(xvii) enabling an actual or proposed assignee, transferee, participant or sub-participant of the Company’s or the Group’s rights or business to evaluate or carry out the transaction intended to be the subject of the assignment, transfer, participation or sub-participation; and

(xviii) any other purposes relating to any of the purposes listed above.

Personal data held by the Company relating to you will be kept confidential but the Company may provide such data to the following parties, whether inside or outside of Hong Kong to fulfil the Purposes:-

(i) any other purposes relating to any of the purposes listed above.

(ii) third-party doctors, healthcare or educational institutions, medical and healthcare service providers or laboratories;

(iii) any agent, contractor or third party service provider, including but not limited to any service provider within the Group, which provides services to the Company in connection with the operation of its business including but not limited to, administrative, telecommunications, computer, payment, data processing, storage, investigation, debt collection, technology outsourcing, mailing and printing services and other services in connection with the Company’s operations, the Products and Services;

(iv) any authorized person or organization in connection with the Products and Services provided by the Company to you (such as your employer, insurance company (or its service provider) or insurance broker);

(v) any other person or entity under a duty of confidentiality to the Company or the Group including any Group Entity which has undertaken to keep such data confidential;

(vi) any person or entity to whom the Company or the Group is under an obligation or otherwise required to make disclosure under the requirements of any law or regulations, code of practice, guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations binding on or applying to the Company or the Group or with which the Company or the Group is expected to comply, or to establish, exercise or defend or to protect legal claims, to protect the rights, property or safety of the Company or the Group, all of which may be within or outside Hong Kong and may be existing currently and in the future;

(vii) any actual or proposed assignee, transferee, participant or sub-participant of the Company’s rights or business;

(viii) third party reward, loyalty, co-branding and privileges program providers;

(ix) co-branding partners and/or marketing partners of the Company and/or any Group Entity (the names of such co-branding partners and/or marketing partners can be found in the registration form(s) and/or promotional material for the relevant services and products, as the case may be);

(x) external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and sales agents, data processing companies and information technology companies) that the Company engages for the purposes set out in paragraph (1)(ix) of this PICS; and

(xi) other companies who help gather your information or communicate with you, such as research companies and ratings agencies, in order to enhance the products or services we make available to you.

From time to time, the Group or the Company may purchase a business or sell one or more of the Company’s business(es) (or portions thereof). In the event that Group or the Company purchase(s) a business, the personal data received with that business would be treated in accordance with this PICS, if it is practicable and permissible to do so. In the event that Group or the Company sell(s) any of the Company’s business(es), provisions will be included in the selling contract requiring the purchaser to treat your personal data in the same manner required by this PICS.

In accordance with the Personal Data (Privacy) Ordinance (the “Ordinance”), you have the right to request access to and the correction of any of your personal data held by the Company, by writing to the Corporate Data Protection Officer of the Company at the following address and email:

According to the Ordinance, the Company has the right to charge a reasonable fee which is directly related to and necessary for the processing of any data access request.