We are committed to protecting the privacy and personal data of our clients, potential clients, website visitors and other individuals with whom we interact. This Privacy Policy explains how we collect, use, disclose, store and protect personal data, and the rights available to you.
This Privacy Policy is issued by CliniVoyage Limited (“CliniVoyage”, “we”, “us”), a company incorporated in Hong Kong, with its registered office at Suite 1704, 17th Floor, The L Plaza, 367-375 Queen's Road Central, Central, Hong Kong. This Policy governs your access to and use of our website, our mobile applications (if any), and the information, materials and services provided through them, as well as all communication between us.
We are committed to protecting the privacy and personal data of our clients, potential clients, website visitors and other individuals with whom we interact. We comply with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the "PDPO") and the Data Protection Principles set out therein, and we will only collect, use, hold or disclose personal data in accordance with the PDPO and this Privacy Policy. This Privacy Policy explains how we collect, use, disclose, store and protect personal data, and the rights available to you.
In this Privacy Policy, "personal data" has the meaning given to it in the PDPO, and means any data: (a) relating directly or indirectly to a living individual; (b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (c) in a form in which access to or processing of the data is practicable. "You" means the individual to whom the personal data relates.
We collect personal data in a number of circumstances, including when you: (a) submit an enquiry, request a consultation, or contact us by any means; (b) engage us to provide coordination services, or your representative engages us on your behalf; (c) provide medical records, investigation results or other health-related documents to us; (d) visit or interact with our website; (e) attend a meeting or consultation arranged by us; or (f) otherwise communicate with us, including by correspondence, telephone, video call, email or instant messaging.
The categories of personal data we collect and the purposes for which we use them depend on the circumstances of collection. We will notify you of the purposes of collection and the classes of transferees at or before the time of collection, in accordance with PDPO section 33 and the Data Protection Principles. In general, we may use and disclose personal data for the purpose for which it was provided, for directly related purposes, and for any other purpose to which you have consented.
(a) Enquiries and consultation requests: we may collect your name, contact details, preferred language, medical concern, preferred timing and any information you choose to provide, and we may use such data to respond to your enquiry, to assess whether we can assist you, and to prepare an initial recommendation.
(b) Coordination services: we may collect your name, gender, date of birth, nationality, passport or identity document details, contact details, emergency contact information, medical records and investigation results, insurance information and billing information. We may use such data to arrange consultations and admissions, to communicate with hospitals and physicians, to arrange certified translation, to verify documentation, to process payments and insurance claims, and to evaluate, plan and improve our services.
(c) Website usage: we collect aggregated, non-identifying information about website activity for business planning and improvement. We use cookies and similar technologies as described in clause 6 below.
Because our services involve coordination with hospitals, physicians and other service providers in the People's Republic of China, your personal data — including health-related data — may be transferred to, and processed in, the People's Republic of China and other jurisdictions outside Hong Kong. Any such transfer is made for the purposes of providing our coordination services, and we will obtain your explicit consent before transferring your personal data outside Hong Kong where such consent is required under the PDPO. We will take all practicable steps to ensure that any recipient outside Hong Kong handles your personal data to a standard at least equivalent to that required by the PDPO.
Our website uses cookies and similar technologies to enhance your browsing experience and to compile aggregated statistics about usage. We do not store personal data in cookies unless strictly necessary for the functionality of the website. You may adjust your browser settings to refuse cookies, although some features of the website may not function properly as a result.
We take all practicable steps to ensure that personal data is protected against unauthorised or accidental access, processing, erasure, loss or use. Our security measures include encryption and password protection of data in our custody, restricted access controls, up-to-date system and anti-malware protection, and security training for our personnel. We retain personal data only for as long as necessary for the purposes for which it was collected, and in any event: medical and coordination records for a period of up to seven years after the conclusion of the engagement; billing and payment records for the period required by applicable law; and contact details used for marketing communications only for as long as you consent to receive them.
You have the right under sections 18 and 22 of, and Principle 6 in Schedule 1 to, the PDPO to request access to, and correction of, personal data held by us, and to be informed of our policies and practices regarding personal data. We may charge a reasonable administrative fee for complying with a data access request, and we may require you to provide suitable proof of identity before processing any request. Requests should be directed to the contact details in clause 10 below. We will respond to any such request within the time limits prescribed by the PDPO.
We will not use your personal data for direct marketing unless you have provided your express consent in accordance with section 6A of the PDPO. If you have consented, you may withdraw your consent at any time by contacting us using the details in clause 10 below, and we will cease using your personal data for direct marketing within a reasonable time. This does not affect our ability to send service-related communications necessary for the performance of an engagement.
We welcome your questions, comments or complaints regarding this Privacy Policy or our handling of personal data. Please contact us at [email protected]. If you are not satisfied with our response to a complaint, you may lodge a complaint with the Privacy Commissioner for Personal Data, Hong Kong (the "Privacy Commissioner").
If you are located in the European Union or the United Kingdom, the General Data Protection Regulation (EU) 2016/679 (the "GDPR") or the UK General Data Protection Regulation (as applicable) provides you with the following additional information and rights: (a) the legal basis for our processing of your personal data is our legitimate interest in providing healthcare coordination services to our clients and developing our business, except where processing is based on your consent, which you may withdraw at any time; (b) you may have additional rights, including the right to data portability and, where applicable, the right to complain to your local data protection authority; and (c) where your personal data is transferred outside the European Economic Area or the United Kingdom, we will take appropriate safeguards, including standard contractual clauses where required.
We may amend this Privacy Policy from time to time. The current version will be published on our website, and you should check it regularly for changes. Your continued use of our website or services after any amendment constitutes acceptance of the amended policy.
This Privacy Policy is governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region of the People's Republic of China, and you irrevocably submit to the exclusive jurisdiction of the courts of the Hong Kong Special Administrative Region for any dispute arising out of or in connection with this Privacy Policy.
This Policy is written in English and may be translated into other languages as the occasion arises. A Chinese version of this Policy is available on our website. In case of any discrepancy between the English and translated versions, the English version shall prevail.
