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Personal Information Collection Statement

This Personal Information Collection Statement (this “Statement”) is made by Humansa Health (HK) Limited (“Humansa”, “we”, “us”, or “our”), and applies between us and you (“you”, or “your”). This Statement governs the collection, use and transfer of your personal data by Humansa and Humansa Health Service Providers (defined below). This Statement should be read together with the Terms and Conditions (if any) of the Humansa Application and/or other device(s) or application(s) (“Application”) and the relevant website(s) that Humansa and/or the relevant Humansa Health Service Providers may operate from time to time for the relevant services (including, e.g., https://www.humansa.com.hk and https://www.hdendoscopy.hk) (“Website”) (the “Terms and Conditions”), provided that, in the event of any inconsistency between this Statement and the Terms and Conditions concerning matters relating to personal data, this Statement shall prevail.

Humansa is part of a group of companies including Twilight Wood Limited, Trinity Link Limited trading as HD Endoscopy Centre, and their related companies/affiliates/subsidiaries in or outside Hong Kong from time to time as listed here: http://wwwstg.humansahealth.com/pics (together, the “Humansa Health Service Providers”) whose services and activities include health care and senior care, sports and recreational facilities, food and beverages, and the provision of other health and wellness products and services (the “Humansa Goods and Services”).

Humansa and Humansa Health Service Providers are also part of the New World group of companies including New World Development Company Limited and its affiliated or related companies from time to time (as listed here: https://www.nwd.com.hk/pics) (the “New World Group”, or “NWG”) whose activities include real estate (sale, leasing and investment), mortgage services, retail, property management, facilities management, activity planning and management, infrastructure, shopping malls, loyalty programmes, department stores, jewelleries and luxury products, e-commerce, hospitality services, food and beverages, convention and exhibition centres, sports and recreational facilities, education, health care and senior care, other health and wellness products and services, financial services and insurance, transportation, sustainability programmes and products, TMT (Technology, Media and Telecom), corporate innovation, accelerator and incubation programmes, organization of competitions, conferences and events, start up and social innovation programmes and charitable pursuits including sports, recreation, art and cultural programmes, relief of poverty, advancement of education, advancement of religion, and other purposes that are beneficial to the community (the “NWG Goods and Services”) (the New World Group and joint venture companies together referred to as “NWG Affiliates”).

In order to enable Humansa and/or the relevant Humansa Health Service Providers to perform the Purposes (including the Purposes For Collecting Medical Information) (as defined in the “Purposes for using personal data collected” section below) (as the case may be), you are required to provide all the requested/mandatory personal data requested in the relevant forms and/or documents (including but not limited to the patient registration form, personal particulars form, online contact form and/or any other applicable forms and documents that we and/or the relevant Humansa Health Service Providers may issue from time to time, as the case may be). If you do not provide the required personal data, then we and/or the relevant Humansa Health Service Providers may not be able to perform the Purposes (including the Purposes For Collecting Medical Information) and/or provide certain goods or services to you (as the case may be).

If you are under 18 years of age, you should consult with your parent or legal guardian before sharing or providing your personal data to Humansa and/or the relevant Humansa Health Service Providers. To protect your interest as a minor, even if you agree for Humansa and/or the relevant Humansa Health Service Providers to use and disclose your personal data for the relevant purposes as specified in this Statement, we will require your parent or legal guardian to give consent on your behalf before we proceed to so use and disclose your personal data.

Kinds of personal data collected

The kinds of personal data Humansa and/or the relevant Humansa Health Service Providers may collect from you and/or third parties authorized by you include your name, gender, age (or age range), month and date of birth, identity card number (or passport number, where applicable), contact details, e-mail address, mailing/residential/correspondence address, contact number, patient number, membership number, marital status, family status, educational level, occupation, username and password, Log Files (see below), interests and favourite activities, tracking information about your use of the Application and/or the Website (as the case may be) and transaction information (including your characteristics and transaction behaviour) (“Tracking Data”), social media account information, etc. For Tracking Data collected through the use of cookies and other tracking mechanisms, please also refer to our related policies (including but not limited to the New World Group Privacy Policy Statement [and Cookies Policy])for further details as to how we collect, use and process Tracking Data.

Please note that your identity card number (or passport number, where applicable) will only be used for verifying your identity when providing you with service(s) requested from Humansa and/or any of the relevant Humansa Health Service Providers, dealing with your enquiry and registration of the relevant services.

Humansa and/or the relevant Humansa Health Service Providers may also collect from you and/or third parties authorized by you, your health data, health records, medical information, history, condition, drug history and/or other relevant information relating to your health, body and/or medical condition (“Medical Information”), and retain the same for performing the Purposes For Collecting Medical Information.

Purposes for using personal data collected

Your personal data (except for Medical Information) will be used and retained by Humansa and/or the relevant Humansa Health Service Providers (and/or the relevant NWG Affiliates and/or the relevant Marketing Partners as defined in the “Direct Marketing” section below, as applicable) for the following purposes (as may be applicable from time to time) (together, the “Purposes”):

  • Processing your enquiry about us and/or any of the relevant Humansa Health Service Providers, and/or the services and/or related facilities, as the case may be, provided by us and/or any of the relevant Humansa Health Service Providers;
  • Providing you with the relevant services requested from us and/or any of the relevant Humansa Health Service Providers;
  • Contacting you in connection with your enquiry and/or registration of the relevant services from us and/or any of the relevant Humansa Health Service Providers, as the case may be;
  • To process bookings, orders or requests made by you, and send you event or booking reminders; Identifying and verifying your identity and/or as a member;
  • Registering you as a user of the Application and/or the Website (as the case may be);
  • To serve you better and/or maintain your personal data and/or information across multiple pages within or across one or more sessions when using the Application and/or the Website (as the case may be);
  • Following registration as a user, accessing your account information (including, but not limited to, your name, membership number, etc.) and managing your account (including, but not limited to, changing your password, updating your personal information, subscribing/unsubscribing from direct marketing, etc.);
  • Research, development, and analysis in relation to your/customer behaviour including carrying out data sorting and analysis to enable us and/or the relevant Humansa Health Service Providers to better understand your characteristics and transaction behaviour to provide other goods and/or services better tailored to your needs, and to assist us and/or the relevant Humansa Health Service Providers in selecting Marketing Subjects (see below) that are likely to be of interest to you (subject to your consent for direct marketing and cross-marketing), and carrying out aggregated behavioural analysis, including using personal data for statistical analysis, data science studies and data mining;
  • For you to make enquiries, complaints, and/or suggestions to us and/or the relevant Humansa Health Service Providers in relation to the Purposes, the Humansa Goods and Services and/or the NWG Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our and/or the relevant Humansa Health Service Providers’ official social media page and/or official website, or by text message, email and/or mail, and/or other media whether now known or available in the future);
  • Seeking your feedback, including through surveys, in relation to the Purposes, the Humansa Goods and Services and/or the NWG Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our and/or the relevant Humansa Health Service Providers’ official social media page and/or official website, or by text message, email and/or mail, and/or other media whether now known or available in the future);
  • Improving the Application/Website, the Purposes, the Humansa Goods and Services and/or  the NWG Goods and Services;
  • Direct marketing and cross-marketing for the Marketing Subjects, subject to your consent (see below section entitled “Direct marketing”);
  • Data analytics, profiling, information management and database administration;
  • Deterring, detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our policies or may be abusive, illegal, and/or criminal;
  • Collection or recovery of any debt owed by you to us, any of the relevant Humansa Health Service Providers and/or any of the relevant NWG Affiliates;
  • The normal management, operation, and maintenance of the Application, the Website and the provision of the Humansa Goods and Services and/or the NWG Goods and Services to you;
  • Storing your personal data (whether by a single or multiple Humansa Health Service Providers (including us) and/or by a single or multiple NWG Affiliates or Marketing Partners) for the purpose of sharing such personal data amongst us, any of the other relevant Humansa Health Service Providers, the relevant NWG Affiliates and/or the relevant Marketing Partners (as the case may be) for any and all of the other Purposes listed above (and subject to your consent in the event that transfer to any or all such data transferees for direct marketing are involved); and/or
  • Other purposes ancillary or related to the above.

For the avoidance of doubt, where applicable or the context so admits, the general references to “Purposes” in this Statement shall also include references to the specific “Purposes For Collecting Medical Information” (see below).

The Medical Information to be collected from you and/or third parties authorized by you will be used and retained by Humansa and/or the relevant Humansa Health Service Providers only for the following purposes (as may be applicable from time to time) (together, the “Purposes For Collecting Medical Information”):

  • Providing you with the relevant services requested from Humansa and/or any of the relevant Humansa Health Service Providers;
  • Direct marketing and cross-marketing for the Marketing Subjects conducted by Humansa and/or any of the relevant Humansa Health Service Providers, subject to your consent (see below section entitled “Direct marketing”);
  • Data analytics and statistics; and/or
  • Other purposes ancillary or related to the above.

Those with whom personal data is shared with

Your personal data (and some or all of your Medical Information, if/where applicable) may from time to time be provided by Humansa to the relevant Humansa Health Service Providers for performing the relevant Purposes (including, subject to your consent, performing the relevant Purposes For Collecting Medical Information, if/where applicable), and also subject to your consent, for performing direct marketing and/or cross marketing for the Marketing Subjects (see below section entitled “Direct marketing”), as the case may be.

Humansa and/or the relevant Humansa Health Service Providers may engage agents, contractors, suppliers and service providers (whether within or outside the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”)) in connection with the Purposes and/or the provision of the Humansa Goods and Services, e.g. IT/software solutions/technology services providers, marketing agents, social media, research companies, and service providers of development and maintenance, administrative, data processing, digital storage, or other similar services (together, “Third Party Service Providers”), and may transfer to or share your personal data (except for Medical Information) with them for the Purposes within or outside Hong Kong. Humansa and/or the relevant Humansa Health Service Providers may also share your personal data (except for Medical Information) (subject to your consent, if/where applicable) with the relevant NWG Affiliates, the relevant Marketing Partners (see below) and the social media platforms that we, the relevant Humansa Health Service Providers, the relevant NWG Affiliates and/or the relevant Marketing Partners (see below) use for such Purposes. We and/or the relevant Humansa Health Service Providers may also share your Medical Information with Third Party Service Providers solely for their provision of data analytics, maintenance, administrative, data processing, data storage or other support services necessary to enable Humansa and/or the relevant Humansa Health Service Providers to carry out the relevant Purposes For Collecting Medical Information with your consent, but not for any other purposes or usages whatsoever.

Where Humansa and/or the relevant Humansa Health Service Providers are required by the law of any country or place or requested by any court, regulatory body or governmental body of any country or place, we and/or the relevant Humansa Health Service Providers may also disclose your personal data as required.

In the event of any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer, or purchase of Humansa, any of the relevant Humansa Health Service Providers or our/their respective businesses, your personal data may be transferred to the new entity as part of the transaction, provided that the new entity abides by this Statement and continues to exercise the same level of care, in respect of your personal data, as we and/or the relevant Humansa Health Service Providers would. You will be notified of such event and you may decide to withdraw your consent to the use of your personal data.

Your personal data (including Medical Information) may be stored by us and/or the relevant Humansa Health Service Providers in physical locations and/or servers located within or outside Hong Kong. Your personal data (excluding Medical Information) may be stored by and shared with the relevant NWG Affiliates and/or the relevant Marketing Partners (see below) located within or outside Hong Kong. However, we and/or the relevant Humansa Health Service Providers will take all reasonable measures to ensure that your personal data (including Medical Information) is stored and processed securely, regardless of the country or place in which it is stored, and we and/or the relevant Humansa Health Service Providers will procure by contract or use our reasonable endeavours to ensure that the relevant NWG Affiliates and the relevant Marketing Partners (see below) do the same.

Direct marketing

Subject to your consent, Humansa and/or the relevant Humansa Health Service Providers may use your personal data (including Medical Information), and may conduct the relevant intra-group data transfers amongst the relevant Humansa Health Service Providers (including us), to send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, any of the relevant Humansa Health Service Providers, the relevant NWG Affiliates and/or the relevant Marketing Partners (see below) in relation to the Marketing Subjects (see below), whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, or other media whether now known or available in the future (together, “Communication Channels”).

Subject to your consent, Humansa and/or the relevant Humansa Health Service Providers may also transfer your personal data (excluding Medical Information) to the relevant NWG Affiliates and/or the relevant Marketing Partners (see below) so that they may send you direct marketing (including, but not limited to, special offers, news, information and marketing) about themselves, Humansa and/or the relevant Humansa Health Service Providers in relation to the Marketing Subjects (see below), whether by any of the Communication Channels.

The marketing partners of Humansa and/or the relevant Humansa Health Service Providers include property developers, banks, financial and investment institutions, insurance companies, private clubs, concierge and customer service providers, retail outlets and online businesses (products and services including fashion and beauty, health and personal cares, luxury, home and living, food, wine and beverage, books and stationery), shopping malls, department stores, watches and jewellers (such as Chow Tai Fook Jewellery Group Limited), hotel chains, catering services providers, healthcare and senior care, services and/or products providers including health and wellness, art and culture, gallery and exhibition, green and nature, sports and recreation, travel and accommodation, leisure and entertainment, transportation and logistics, telecommunication, media and information technology, corporate innovation, accelerator and incubation programmes, competitions, conferences and events, pre-school, primary, secondary and/or tertiary education institutions (“Marketing Partners”).

As Humansa and/or the relevant Humansa Health Service Providers may share your personal data (excluding Medical Information) with the relevant NWG Affiliates and/or the relevant Marketing Partners, we and/or the relevant Humansa Health Service Providers may also receive your personal data from them. Subject to your consent given to the relevant NWG Affiliates and/or Marketing Partners, we and/or the relevant Humansa Health Service Providers may also use such personal data to send you direct marketing about us and/or the relevant Humansa Health Service Providers, any of the relevant NWG Affiliates and/or Marketing Partners in relation to the Marketing Subjects (see below).

Subject to the restrictions as set out in the next paragraph regarding certain exclusions of Medical Information from use and/or transfer for direct marketing, the types of products, services, events and charitable initiatives that Humansa, the relevant Humansa Health Service Providers, the relevant NWG Affiliates and/or Marketing Partners (as the case may be) may market to you include the following (together, the “Marketing Subjects”):

  • goods and services offered by us and/or the relevant Humansa Health Service Providers in relation to the Humansa Goods and Services;
  • goods and services offered by our NWG Affiliates in relation to the NWG Goods and Services; pharmaceutical products, medical and pharmaceutical services, therapists;
  • consumer products and services by retail outlets and/or online businesses, including health and personal cares, baby products and sports;
  • gym and fitness services;
  • reward, loyalty, privileges programmes and promotions; medical services;
  • professional advice and/or consultation on personal enhancement;
  • charitable initiatives which support areas including sports, recreation, art and cultural programmes relief of poverty, advancement of education, advancement of religion and other purposes that are beneficial to the community.

For the avoidance of doubt, none of your Medical Information will be used by Humansa and/or any Humansa Health Service Providers, and/or transferred to any NWG Affiliates and/or any Marketing Partners, for or in relation to direct marketing of those Marketing Subjects (including but not limited to direct marketing of NWG Goods and Services) where it is unnecessary, excessive or otherwise unjustified to use such Medical Information for direct marketing.

Humansa and/or any of the relevant Humansa Health Service Providers cannot use or provide your personal data (including Medical Information, if/where applicable) for direct marketing purposes and/or provide your personal data (excluding Medical Information) to third parties (whether to our NWG Affiliates and/or the Marketing Partners) for their direct marketing purposes unless you consent. Even if you give your consent, you can opt out of direct marketing at any time (or you may request that we cease to provide your personal data to third parties, at which point we will cease to do so), free of charge, by writing to our Personal Data Privacy Officer at 30th Floor, New World Tower, 18 Queen’s Road Central, Hong Kong, or by email to privacy@humansa.com.hk or privacy@nwd.com.hk (marked Confidential).

Your rights

Apart from your right to opt out of direct marketing as mentioned above, you have the following additional rights to:

  • check whether Humansa and/or the relevant Humansa Health Service Providers hold any of your personal data;
  • access your personal data held by Humansa and/or the relevant Humansa Health Service Providers;
  • require Humansa and/or the relevant Humansa Health Service Providers to correct any personal data which is inaccurate;
  • ascertain the policies and practices (from time to time) in relation to personal data and the types of personal data held by Humansa and/or the relevant Humansa Health Service Providers.

If you would like to make a request in relation to the above (or make any general enquiries), please contact our Personal Data Privacy Officer at 30th Floor, New World Tower, 18 Queen’s Road Central, Hong Kong or by email to privacy@humansa.com.hk or privacy@nwd.com.hk (marked Confidential). In accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the “PDPO”), we have the right to charge you a reasonable fee for the processing of any personal data access request.

Privacy Policy Statement

Humansa and/or the relevant Humansa Health Service Providers adopt the New World Group Privacy Policy Statement. You can find out more about Humansa and/or the relevant Humansa Health Service Providers’ policies on personal  data  protection  by  accessing  the  New  World  Group  Privacy  Policy  Statement  available at https://www.nwd.com.hk/privacy-policy. If there is any inconsistency or conflict between the New World Group Privacy Policy Statement and this Statement, this Statement shall prevail.

Please also see the New World Group Privacy Policy Statement for Humansa and Humansa Health Service Providers’ policies and information about:

  • Humansa and/or the relevant Humansa Health Service Providers’ collection and/or use of Log Files (data relating to your use of/visits to the Application and/or the Website (as the case may be), including but not limited to your IP address, domain name, browser type and access time);
  • the use of cookies and other tracking mechanisms;
  • retention of your personal data;
  • third party merchants and/or websites that may be contained in the Application and/or the Website (as the case may be);
  • how Humansa and/or the relevant Humansa Health Service Providers keep your personal data secure;
  • use of your personal data in legal proceedings.

Inconsistency or conflict

If there is any inconsistency or conflict between the English and Chinese version of this Statement, the English version shall prevail.

Miscellaneous

This Statement may be updated from time to time to reflect changes to Humansa and/or the relevant Humansa Health Service Providers’ policy with respect to personal data protection and/or changes to personal data/data privacy laws and regulations. Where there are significant changes, we and/or the relevant Humansa Health Service Providers (as the case may be) will notify you and obtain your acceptance of the changes, consents, and/or opt in (as necessary or applicable). If you do not accept the changes and/or provide your consent, then we and/or the relevant Humansa Health Service Providers (as the case may be) may not be able to perform the Purposes and/or provide goods or services to you. You are advised to check the Application and/or the Website (as the case may be) for updates to this Statement on a regular basis.

Nothing in this Statement shall limit your rights under the PDPO.

PRC Addendum

If you are:

  1. an individual located in Mainland China who uses the Application or visits the Website of Humansa and/or the relevant Humansa Health Service Providers, or otherwise provides personal data to us and/or the relevant Humansa Health Service Providers by phone or any other means from Mainland China whether for making enquiries, reservations or otherwise; and/or
  2. an individual holding a Mainland China passport and/or resident identity card who visits our and/or the relevant Humansa Health Service Providers’ physical centres in Hong Kong or otherwise uses our and/or the relevant Humansa Health Service Providers’ products and/or services by phone or any other means in Hong Kong,


your personal data will be processed by Humansa and/or the relevant Humansa Health Service Providers in accordance with the “People’s Republic of China Addendum” in addition to the respective Privacy Policy Statement of Humansa and/or the relevant Humansa Health Service Providers all of which adopt the New World Group Privacy Policy Statement, the New World Group Privacy Policy Statement and this Statement, as well as the applicable data protection laws and regulations in Mainland China, which for the current purposes, excludes Hong Kong, the Macau Special Administrative Region of the People’s Republic of China and Taiwan.

This Statement shall be governed by, and construed in accordance with, the laws of Hong Kong.

Version: 28 April 2023