Personal Information Collection Statement (“Statement”) relating to the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”)
1.1 Quality HealthCare Group Limited (“QHMS”, “Company”, “we” or “us”) is committed to protecting the privacy and security of your personal information. This Statement is provided to you in connection with your dealings and provision of data or information to QHMS entities including, without limitation, Quality HealthCare Medical Centre Limited, Quality HealthCare Medical Services Limited, Quality HealthCare Dental Services Limited, Quality HealthCare Diagnostic & Imaging Services Limited, Central Medical Diagnostic Centre Limited, Alpha Medical MRI (TST) Limited, Quality HealthCare Professional Services Limited, Quality HealthCare Chinese Medicine Services Limited, Eplushealth Limited and Quality HealthCare Nursing Agency Limited. Unless advised otherwise, all references to QHMS, “Company”, “we” or “us” in this Statement includes, individually or collectively, QHMS entities located in Hong Kong that process personal data as data users. The rights and obligations of each Company under this Statement are several and not joint. No Company shall be liable for any act or omission by another Company.
1.3 For the purposes of this Statement, “Group Company” means Company and its holding companies, branches, subsidiaries, representative offices and affiliates, wherever situated, and any one of them. Affiliates include branches, subsidiaries, representative offices and affiliates of the Company’s holding companies, wherever situated (collectively, the “Group”).
1.5 Failure to supply personal information requested by the Company may result in the Company being unable to process your application, request for information or services, enquiries and/or provide services or products to you if the processing of such personal information is necessary for such purpose(s).
2. Personal Information We Collect
2.1 The Company may collect your personal information for the purposes as set out in this Statement.
2.2 The personal information we collect and/or hold from time to time may include your personal identification information, contact information, transaction records, financial background, medical and health records, biometric data and your location and activities when you access or browse our website(s) or use our mobile application(s) or portal(s) (including any diagnostic or health-monitoring tools thereon and the Bluetooth and/or wearable device that are used to collect data for the purposes of such tools) .
3. Purposes of Collection
3.1 Your personal information collected may be used, stored, processed, transferred, disclosed or shared by the Company for the following purposes from time to time:
(a) processing, accessing and determining any applications or requests, enquiries or complaints for or in relation to the services or products provided by us;
(b) registering you as a user or a member of services or information provided or to be provided by us on the website(s), mobile application(s) or portal(s) managed and/or operated by us;
(c) verifying your identity before providing our products or services to you;
(d) providing you with personalised medical information, health information and information about our services or products, and personalised website, mobile application or portal interface;
(e) providing you with appropriate medical, health, insurance administration, wellness or other related services (including, without limitation, e-ticketing, appointment booking and clinic / medical professional search and service and product redemption functions on the website(s), mobile application(s) or portal(s)) managed and/or operated by us) or products;
(f) communicating with you regarding the administration, features and renewal of the medical, dental or health services plans that you subscribe to;
(g) operating, maintaining, evaluating, improving, troubleshooting problems, and understanding your preference(s) with our website(s), mobile application(s) or portal(s);
(h) providing telemedicine and related healthcare services electronically to you;
(i) processing billing and payments or collecting outstanding amounts due from you;
(j) performing any functions and activities related to the services or products provided by the Company including, without limitation, audit, reporting, marketing research, general servicing, maintenance of online and other services, identity verification, data matching, research, data analytics and statistical analysis;
(k) exercising the Company’s rights in connection with the provision of medical, health, insurance, wellness or other related services or products to you;
(l) managing our relationship with you, our business and organisations who work with us in relation to providing our products or services to you;
(m) marketing services, products and other subjects by us, any member of the Group Companies and/or other third parties (please see further details in paragraph 5 below);
(n) making disclosure to satisfy the requirements of any laws, rules and regulations, codes of practice, guidance notes or guidelines binding on the Company;
(o) communication with you in relation to any of the purposes set out in this Statement; and
(p) fulfilling any other purposes directly related to (a) to (o) above.
4. Transfer of Personal Information
4.1 Personal information collected or held by the Company relating to you will be kept confidential, but the Company may transfer such personal information inside or outside the Hong Kong Special Administrative Region of the People’s Republic of China, for the purposes specified in paragraph 3 above to the following classes of transferees:
(a) any member of the Group Companies who provides medical, health, insurance, wellness or other related services or products;
(b) any third parties engaged in connection with the a member of the Group Company’s business who provides medical, health, insurance, wellness or other related services or products;
(c) any agent, contractor or other third party service providers who provides administrative, telecommunications, computer, payment, data processing, storage of analytics, printing, research, telemedicine, distribution or other services to the Company in connection with the operation of the business (including, without limitation, insurers, banks, lawyers and accountants);
(d) any member of the Group Companies (such as Bupa (Asia) Limited, our affiliate) or third parties involved in the marketing of services, products and other subjects (please see further details in paragraph 5 below);
(e) third party reward, loyalty, co-branding and privileges programme providers and co-branding partners of a member of the Group Companies;
(f) financial institutions engaged by the Company or you for billing and payment purposes;
(g) any actual or proposed assignee, transferee, participant or sub-participant of all or a substantial part of our rights or business; and
(h) any person to whom the Company is under an obligation to make disclosure under the requirements of any law, rules, regulations, codes of practice or guidelines binding on us including, without limitation, any applicable regulators, governmental bodies, industry recognised bodies, the Courts, and where otherwise required by law.
4.2 We will only disclose personal information limited to that which is necessary to the above parties for the relevant purposes, who may process (including, without limitation, by recording, organising, structuring, storing, adapting, altering, retrieving, using, aligning, combining or erasing) your personal information for the relevant purposes set out in paragraph 3 above.
5. Use of Personal Information in Direct Marketing
5.1 Only with your consent (which includes an indication of no objection), the Company, any member of the Group Companies and/or the third parties stated under paragraphs 3.1(m) and 5.2(b) to (e) may use your personal information collected from time to time to provide you with marketing communications (including by email, SMS, mobile application notification or instant messenger) relating to the following services or products:
(a) insurance, medical, dental, healthcare, wellness, personal development, beauty, lifestyle, entertainment, financial, and related services and products;
(b) rewards, benefits, discounts, member activities, loyalty or privileges programmes and related services and products;
(c) services and products offered by the Company’s co-branding partners; and
(d) donations and contributions for charitable and/or non-profit making purposes.
5.2 The above services, products and subjects may be provided or (in the case of donations and contributions) solicited by the Company and/or:
(a) any member of the Group Companies;
(b) third party service providers;
(c) third party reward, loyalty, co-branding or privileges programme providers;
(d) co-branding partners of a member of the Group Companies; and
(e) charitable or non-profit making organisations.
5.3 We may not use your personal information for direct marketing purposes unless we have received your consent.
5.4 If you choose to personalise your services where such options are available, we will use personal information that we collect so that we can offer you those personalised services or communications. If you do not wish to accept those personalised services or communications, you can unsubscribe from those services at any time and we will cease to offer such services to you.
6. Security and Retention
6.1 The Company retains your personal information for as long as necessary for the purposes set out in this Statement, or otherwise agreed between you and us, unless otherwise required or permitted under applicable law.
6.2 Where the Company no longer requires your personal information for the purposes under this Statement, or otherwise required under law, we will take appropriate steps to securely delete or destroy your personal information.
7. Data Access and Correction
7.1 You have the rights to:
(a) check whether the Company holds personal information relating to you and to access such personal information;
(b) require the Company to correct any personal information relating to you which is inaccurate;
(c) ascertain our policies and practices in relation to personal data and to be informed of the kind of personal data held by the Company;
(d) request the Company to cease using and/or processing your personal information; and
(e) change your preference in respect of our use of your personal information.
7.2 To exercise the above rights, please send your request in writing to:
Data Privacy Officer / Customer Service Manager
6/F, Tower 2
The Quayside, 77 Hoi Bun Road
Kwun Tong, Kowloon
Or, by email:
7.3 We are entitled to charge a reasonable fee for processing your personal data access request.
8. Electronic Health Record Sharing System
9. Nothing in this Statement shall limit your rights under the Ordinance.
10. In case of discrepancies between the English and Chinese versions of this Statement, the English version shall prevail.
11. This Statement may be amended by the Company from time to time.