Union Medical Healthcare Privacy Policy

Union Medical Healthcare refers to Union Medical Healthcare Limited and its subsidiary and affiliated entities, singly or together (hereinafter referred to as “we”, “us”, “our”, our “Group” or “UMH”), presents this “Union Medical Healthcare Privacy Policy (the “Privacy Policy”). This Privacy Policy applies to all personally identifiable information that we may obtain from the following parties (whether currently or in the future): (i) data subject; (ii) third parties (data of which is related to products and services (collectively referred to as “Products and Services”, and individually as “Products” and “Services”) that have been indicated to us by interested individuals); and (iii) third parties who provide us with such Products and Services. This Privacy Policy does not apply to any personal data that is/are obtained by us for recruitment or employment related purposes.

1. Methods of collection of personally identifiable information

UMH may collect your personally identifiable information via the following method(s):

  • via the website operated by us, including https://umhgp.com/ (i.e. the website where you are browsing such Privacy Policy), and other websites owned or controlled by UMH (collectively referred to as “Websites”);
  • via software applications provided by us, used on or through computers and mobile devices (collectively referred to as “Applications”);
  • via social media platforms controlled by us (collectively referred to as “Social Media Platforms”);
  • via electronic mails that may be linked to this Privacy Policy, sent by us and/or any online or face-to-face communication between you and us;
  • via third parties (e.g. authorized licensors, strategic business partners, landlords and franchisers) and other sources (e.g. public databases, marketing partners and relevant third parties)(collectively referred to as the “Platforms”)

2. Principles of collection of personally identifiable information

UMH respects the privacy of all individuals that use our Platforms. We endeavor to ensure that all our collection, transmission, storage and usage of personally identifiable information is carried out in compliance with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of the Hong Kong Special Administrative Region (“Hong Kong”)) (hereinafter referred to as the “Ordinance”).

3. Types of personally identifiable information collected

The term “personally identifiable information” has the meaning as defined in the Ordinance. It refers to information that can identify you as an individual or associate you with an identifiable individual, including but not limited to your name, gender, age, and identification document number, phone number, fax number, residential address, email address, credit card information, education level, occupation, family income, hobbies and favorite activities, etc. Other information, such as your medical records, medial photos, medical images and medical reports, other product or service preferences, or the number of children; in the event that it is directly associated with any such personally identifiable information, shall be treated as personally identifiable information as subject to this Privacy Policy. You shall not be required to provide any personally identifiable information when you browse or use the Platforms. However, upon registration to use our Products and Services or online content, your personally identifiable information shall be collected by us to enable our provision. You may refuse to provide us with your personally identifiable information, but in this case, we may not be able to provide you with such Products and Services or online content. By providing your personally identifiable information to us, you are consenting to this Privacy Policy.

4. Purpose of collection and use of personally identifiable information (including but not limited to)

  • identifying you and any accounts you hold with us
  • enabling the provision of Products and Services to you (if you do not prefer to receive any administrative notices and communications, such as changes with respect to any account you hold with our Group or future changes with respect to this Privacy Policy, please write to us at Room 2107-08, 21/F., Office Tower, Langham Place, Mong Kok, Kowloon or send us an email at info@umhgp.com)
  • determining and verifying your eligibility for discounts and promotions on our Products and Services
  • processing applications or renewal applications for our business partners’ products and services on your behalf
  • processing insurance claims for our business partners’ products and services on your behalf
  • processing of payment instructions or collection of amounts outstanding from you in relation to the provision of the Products and Services
  • enabling us to store your personally identifiable information so as to prevent you from re-entering it each time you purchase and/or renew a Product or Service
  • order processing, billing and fulfilment
  • direct marketing of our Products and Services (see section headed “6. Direct Marketing” below)
  • direct marketing of the products and services of our business partners (see section headed “6. Direct Marketing” below)
  • designing services for you
  • conducting research, statistical analysis and behavioral analysis
  • customer profiling and analyzing your purchasing preferences
  • enabling you to participate in the interactive features of our Services, including identifying your friends or individuals, and sharing and communicating with them your shopping experience, when you choose to do so
  • making suggestions and recommendations to you and other users of our Products and Services or goods and services that may interest you or them
  • customizing our Platforms and its contents to your particular preferences
  • provisioning of customer services
  • handling your complaints and account enquiries, and handling any claim, action and/or proceedings against our Group or any party
  • fraud prevention and detection
  • auditing purposes
  • making such disclosures as required by applicable laws, rules and regulations
  • any other purposes directly related to the purpose for which the personally identifiable information was originally collected

Any questions, comments, suggestions or information other than personally identifiable information that is sent or posted to any part of our Platforms by you will be considered as voluntarily provided to our Group on a no-confidential and non-proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish and/or post elsewhere such information freely, including passing it to any associated company for example, in connection with the development and marketing of services and to meet user needs.

We may take your personally identifiable information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalising your personally identifiable information). We may use this non-personally identifiable information for, among other purposes, research and analysis to improve our Products and Services.

If you purchase our business partners’ products or services including without limitation insurance products, your personally identifiable information will be transferred to that business partner and such information will be used, processed and stored in accordance with that business partner’s privacy policy of which is outside our control. Please refer to the relevant privacy policy of our business partner.

If necessary, we may transfer your personally identifiable information to places outside of Hong Kong for carrying out the purposes, or the directly related purposes, for which the personally identifiable information is to be collected. All such transfers will be carried out in compliance with the requirements of the Ordinance.

5. With whom may we share your personally identifiable information as collected?

All personally identifiable information will be kept confidential, but we may disclose such information to third parties where such disclosure is necessary to fulfil one or more of the purposes described in section 4 of this Privacy Policy. A list of classes of persons (who may be located within or outside of Hong Kong) to whom your personally identifiable information may be transferred can be found at the List of Potential Transferees of Personally Identifiable Information as stated below.

From time to time, we may purchase a business or sell or more of our businesses (or portions thereof) and your personally identifiable information may be transferred as part of the purchase or sale. In the event that we purchase a business, the personally identifiable information received with that business would be treated in accordance with this Privacy Policy, if it is practicable and permissible to do so. In the event that we sell a business, we will include provisions in the selling contract requiring the purchaser to treat your personally identifiable information in the same manner required by this Privacy Policy (including any amendments to this Privacy Policy). In light of this protection, your opt-out choices stated in section 6 of this Privacy Policy shall not affect our right to transfer your personally identifiable information to a purchaser in these circumstances.

6. Direct Marketing

From time to time, the Group may use your personally identifiable information to send you news, offers, promotions and joint marketing offers and the Group requires your consent for that purpose. We may contact you by email, in-app notifications, social media, SMS, text/picture/video message, telephone or mail. Your name, email address, telephone number, contact address, social media contact, date of birth, Products and Services portfolio information, transaction patterns and behaviors, browsing records, content viewing habits and personal interests held by the Group may be used by the Group in direct marketing of our Products and Services and products and services offered by our business partners, including without limitation beauty, skincare and cosmetic products and services, which may be of interest to you.

You may decide to “opt in” to, or to “opt out” from, use by us of your personally identifiable information for promotional and marketing purposes. If you prefer not to receive any direct marketing communications from us, you can opt out at any time by updating your preferences through your registered account or an unsubscribed link as provided by us. You can also write to us or send us an email at the addresses as listed in section 4 above. Any such request shall state clearly the relevant personally identifiable information that you would like to opt out for. Upon receipt of the request, we shall cease to use your personally identifiable information for the purpose of direct marketing as soon as possible without extra charges.

7. Use of Cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access the Group’s Websites and/or Applications. We use cookies on such Platforms to:

  • recognize you whenever you visit the Websites
  • obtain information about your preferences, viewing and browsing behaviour, online movements and use of the Internet
  • keep track of the items stored in your account and take you through the checkout process
  • carry out research and statistical analysis to help improve our Products and Services and to help us better understand our visitor and customer requirements and interests
  • target our marketing and advertising campaigns and those of our business partners and advertisers more effectively by providing interest-based advertisements that are personalised to your interests
  • make your online experience more efficient and enjoyable
  • enable tighter security

The information we obtain from our use of cookies may not contain your personally identifiable information. Although we may obtain information about your computer or other electronic device such as IP address, browser settings, browsing records, and/or other Internet log information, this may not be able to identify you personally. To the extent that non-personally identifiable information is combined with personally identifiable information, we treat the combined information as personally identifiable information for the purposes of this Privacy Policy. In certain circumstances we may collect such personally identifiable information about you, but only where you voluntarily provide it by completing an online form, or where you purchase Products and Services from our Websites and/or Applications.

If you want to disallow the use of cookies, you can do so on your own web browser or electronic device. If you disable cookies, you acknowledge that you may not be able to use some of the functionality of our Websites and/or Applications.

8. Security measures taken to safeguard your personally identifiable information

The security and confidentially of your personally identifiable information is extremely important to us. We have implemented technical, administrative, and all reasonable and practicable measures to protect your personally identifiable information from any unauthorized access and improper use. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware that despite our best efforts, no security measures are perfect or impenetrable.

9. Retention of your personally identifiable information

We will not keep your personally identifiable information longer than is necessary for the fulfillment of the purpose (including any directly related purpose) for which the information is or is to be used. This means that, for example, personally identifiable information collected to fulfill your request for Products and Services will be erased, deleted, destroyed or anonymized after their delivery by using technical or other means to render such information unidentifiable or unusable, unless it is necessary to keep such information for other purposes and we have informed you of such other purposes at the time of collection of the personally identifiable information or obtained your consent.

10. Amendment(s) to this Privacy Policy

We may amend this Privacy Policy at any time. If we amend this Privacy Policy to permit material changes in the way we collect, use and/or share your personally identifiable information, we will notify you of such changes by sending you an email at the last email address that you provided to us, and/or by prominently posting notice of such changes on our Website at https://umhgp.com/. Any such material changes to this Privacy Policy will be effective thirty (30) calendar days following either our dispatch of an email notice to you or our posting of notice of the changes on our Website. Any material changes to this Privacy Policy may affect our use and sharing of personally identifiable information that we collected before our notification to you of the said changes. If you do not wish to permit material changes in our collection, use or sharing of your personally identifiable information collected by us before the effective date of such changes, you must so notify us before that effective date by writing to us or sending an email to us at the addresses listed in section 4 above. Please be advised, however, that, regardless of whether you provide such notice to us, the changes to this Privacy Policy shall apply to any personally identifiable information collected by us on or after the effective date of such changes.

11. Questions and/or comments with respect to this Privacy Policy

If you have any questions or wish to send us any comments, about this Privacy Policy, or wish to complain to us, correct, access a copy of or cease the use of your personally identifiable information, please write to us at the address listed in section 4 above or send us an email at info@umhgp.com. You may also call us at our Customer Services Enquiry at (+852) 8203 0058 during business hours. In the event that any of your questions, comments, complaints and/or demands relates to and/or involve such illegal or inaccurate information, please understand that we may not be able to process such requests. Nonetheless, we shall follow up within reasonable time upon receipt of your questions, comments, complaints and/or demands.

Our Group reserves the right to charge you a reasonable fee for complying with a data access request as permitted by the Ordinance.

The terms of this Privacy Policy are governed by and interpreted in accordance with the Laws of Hong Kong.

In the event of any discrepancy or inconsistency between the English and Chinese versions of this Privacy Policy, the English version shall prevail.

Date of Last Revision: 02 Feb 2021

List of Potential Transferees of Personally Identifiable Information

Parties to whom personal identifiable information collected by us may be transferred:

  1. Governments, law enforcement authorities, courts and tribunals.
  2. Legal and other professional advisors, insurers, loss adjustors, rehabilitation service providers.
  3. Any third party whom you have authorized to obtain your personally identifiable information from the Group, including without limitation agents, contractors or third party service providers who provide Products and/or Services to us or have any form of business partnership with us.