Personal Information Collection Statement

Personal Information Collection Statement (PICS) for Fullerton Health Hong Kong Limited and its Group Compan(ies) registered in Hong Kong.

1. Introduction & Scope

Commitment: Fullerton Health Hong Kong Limited and its Group Compan(ies) registered in Hong Kong (“Company, we, us, or our”) is committed to protecting the privacy, security, and confidentiality of your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (“Ordinance”) and the Electronic Health Record Sharing System Ordinance (Cap. 625) of Hong Kong.
Application: This Personal Information Collection Statement (“PICS”) applies to all personal data collected, stored, used, processed, transferred, disclosed, or shared by us through our websites, mobile applications, portals, clinics, medical centres, and associated services.
Parent/Guardian Consent: If you are under the age of 18, you must obtain consent from your parent or guardian before providing your personal information to us.
Third-Party Information: If you provide us with personal information about other individuals, you must ensure they are informed that you have provided their details and where they can find a copy of this PICS.
Prerequisite: Supply of personal information is voluntary, but failure to supply necessary data may result in our inability to process applications, requests, enquiries, or provide medical, healthcare, or related services.

2. Personal Data We Collect

We may collect and hold various types of personal information, including:

Personal identification information (e.g., name, portrait, date of birth, HKID/passport details).
Contact information (e.g., address, phone number, email address).
Medical and health records, clinical images, diagnostic reports, biometric data, and insurance coverage.
Financial background, billing information, and transaction records.
Digital and technical data: Location, device details, and user activities when accessing our websites, mobile applications, or portals (including data collected via diagnostic/health-monitoring tools, Bluetooth, or wearable devices).

3. Purposes of Collection

Your personal data may be used, stored, processed, transferred, disclosed, or shared by the Company for the following purposes from time to time:

Accessing medical records, coordinating patient care across Fullerton Health Hong Kong entities, and transmitting reports to provide necessary medical care and services.
Sharing medical records with third-party referral doctors as required for referral purposes.
Verification of your identity before supplying medical, healthcare, insurance, or related products and services.
Registering and managing you as a user or member on our websites, mobile applications, or portals (including e-Card, appointment booking, search functions, and service/product redemptions).
Maintaining accurate medical records and ensuring comprehensive assessment/future care.
Providing appropriate medical, dental, health, wellness, telemedicine, or insurance administration services.
Processing billing, payments, and collecting outstanding amounts, or conducting investigations relating to insurance policies, employee health benefit plans, and dependent coverage.
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.
Fulfilling legal, regulatory, compliance, and reporting requirements, or responding to lawful requests by courts, regulators, and government bodies.
Fulfilling any other purposes directly related to all points above

4. Transfer and Disclosure of Personal Data

We will keep your personal data confidential, but may transfer or disclose it (within Hong Kong) to the following classes of transferees for the purposes specified above:

Subsidiaries, affiliates, associates, holding companies, and brands within our corporate group.
Third-party referral doctors, medical personnel, and business partners.
Employers, brokerage firms, and insurance companies that have business dealings with us or are paying for your services.
Agents, contractors, or third-party service providers under a duty of confidentiality who provide administrative, data processing, telecommunications, computer, payment, research, telemedicine, printing, distribution, or professional services.
Third-party reward, loyalty, co-branding, and privileges programme partners.
Financial institutions engaged by the Company or you for billing and payment purposes;
Actual or proposed assignees, transferees, or participants of our business or rights (e.g., in connection with a merger, acquisition, or corporate restructuring).
Any person to whom we are under an obligation to make disclosure under applicable laws, regulations, codes of practice, or court orders.

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 Data in Direct Marketing

Consent Requirement: We will only use your personal data (including name and contact details) for direct marketing purposes with your explicit consent (or an indication of no objection).
Scope: Marketing communications may relate to healthcare, wellness, beauty, lifestyle, insurance, financial services, member privileges, loyalty programmes, co-branded products, and charitable donations offered by Fullerton Health Hong Kong, its group entities, or trusted business partners.
Opt-Out / Unsubscribe: If you agree to receive marketing communications but wish to stop receiving them, you may opt out at any time, free of charge, via:
- Following unsubscribe instructions or hyperlinks in SMS, text messages, or emails.
- Following instructions within mobile applications.
- Notifying us during marketing calls.
- Contacting our Data Protection Officer in writing by post or email.
- Note: The latest instruction received from you will override any previous marketing preferences.

6. Use of Cookies and Tracking Technologies

We and third-party partners use cookies, pixel tags, and similar technologies to improve website/app navigation, remember user preferences, analyze site traffic, and deliver tailored content.
Most web browsers automatically accept cookies, but you can modify your browser settings to decline them (though this may limit interactive site features).

7. Security and Retention

We implement robust digital, physical, and administrative security measures (including restricted access) to safeguard your personal data.
Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, or as required/permitted by law, after which it will be securely deleted or destroyed.

8. Data Access, Correction, and Enquiries

In accordance with the Ordinance, you have the right to:

Ascertain our policies and practices in relation to personal data and the types of personal data held by us.
Access and request a copy of your personal data held by us.
Require us to correct any inaccurate personal data.
Request that we cease using and/or processing your personal data.

Contact Details for Requests: Any requests for access, correction, or privacy enquiries should be made in writing (by post or email) and addressed to:

Fullerton Health Hong Kong Limited and its group entities registered in HK – Data Protection Officer Address: Fullerton Health Hong Kong Limited, Unit 815-817, 8/F., Seapower Tower, Concordia Plaza, 1 Science Museum Road, Tsim Sha Tsui East, Kowloon, Hong Kong

Email: dpo@fullertonhealth.com

In accordance with the Ordinance, we reserve the right to charge a reasonable fee for processing any data access requests.

Nothing in this PICS shall limit your statutory rights under the Personal Data (Privacy) Ordinance.