“GemVCare Limited” is a medical testing company located in Unit 628, Biotech Centre 2, 11 Science Park West Avenue, Hong Kong Science Park, Shatin, Hong Kong. We respect personal data privacy and are committed to full implementation of and compliance with the data protection principles and all relevant provisions of the Hong Kong Personal Data (Privacy) Ordinance (Cap.486) (“Ordinance”). We shall ensure that our staff handling personal data will comply with the legally required standards of security and confidentiality.

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I. PERSONAL DATA COLLECTION

 

We shall at all times fully observe the Ordinance in collecting, maintaining and using your personal data. In particular, we shall follow the following principles, unless otherwise required, permitted by law or agreed by you:

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1. Collection
    

   1. You may be invited to provide personal data to us on a voluntary basis and we will collect personal data from you for lawful purposes relating to:

       

      • subscription to our testing service;

      • specimen and report identification;

      • generation of testing results;

      • internal improvement work including but not limited to R&D and quality control;

      • provision of our services or products to you; and

      • facilitating your access to the information and services in our application and website (the “Platform”).
         

   2. We will collect personal data from you directly through the Platform or by other means which are lawful and fair in the circumstances; and
       

   3. We will take practical steps to ensure that your personal data are and remain accurate, but your assistance may be required to enable us to know if there is any change.
       

2. Use
    

   1. Your personal data will be used for the purposes specified herein, including those set out in paragraph I(1)(1) above; and
       

   2. We will not be using your personal data for other purposes without your consent.
       

3. Storage
    

   1. We will take practical steps to ensure that your personal data will be destroyed immediately after the applicable prescribed retention period and will not be kept longer than necessary; and
       

   2. We will take practical steps to ensure that your personal data will be protected against unauthorised or accidental access, processing or erasure.
       

4. Security
    

   1. We will take all practical steps to ensure that your personal data are protected against unauthorized and accidental access and loss.
       

   2. We may from time to time engage one or more data processers, whether within or outside Hong Kong, to process your personal data on our behalf, but we will take practical steps to ensure that your personal data will be protected against unauthorised or accidental access, processing or erasure.
       

5. Access
    

   1. You have the right to access and correct your personal data held by us. Your request for access or correction will be dealt with in accordance with the Ordinance. You may contact us in the manner specified in “Contact Us” section for such purpose.
       

   2. Your personal data is classified as confidential and can only be disclosed by us in the manner specified herein or where we are permitted by the Ordinance or otherwise legally compelled to do so.You are not obliged to provide the personal data that we have requested, but you may be unable to access some of the information or services on this Platform and we may be otherwise unable to provide some or all of our services or products to you or to respond to any queries you may have without your personal data.

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You are not obliged to provide the personal data that we have requested, but you may be unable to access some of the information or services on this Platform and we may be otherwise unable to provide some or all of our services or products to you or to respond to any queries you may have without your personal data.

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II. COLLECTION OF INFORMATION

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1. When you make registration with us for purposes such as enquiries of and appointment for our service, you will be required to give us your personal data (such as your name, surname, phone number and email). We may also collect payment related information (such as credit card details) and other personal information that we believe to be relevant to the provision of our service to you.
    

2. The Platform and our servers may automatically collect data about your internet address when you visit our website. Like most web servers, we store your IP address in a log file when you visit the Platform. Your IP address is used to help identify you and to gather demographic information about our customers, members and users as a whole. Our server may also record the date, time and referring page that linked you to us (e.g. another website or a search engine); the pages you visit on the website; the website you visit, if any, after the Platform; other information about the type of web browser, computer, related software and settings you are using; any search terms you have entered on the Platform or a referral site; and other web usage activities and data logged by our servers. We use this information for internal system administration, to help diagnose problems with our servers, and to administer our services. This information is for internal use only and will not be given out.
    

3. We may use cookies in some areas of the Platform. Cookies are small pieces of information that we store on your computer’s browser or hard drive. Such information does not contain your name or address information or any information that will enable us to contact you via telephone, e-mail or any other means. The information stored is to enable the Platform to function correctly and give you additional features and benefits such as automatic log in. Most browsers give you the option of preventing cookies from being stored on your computer, though doing so may cause you to lose some of the benefits of the Platform.

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III. USE OF INFORMATION

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1. Your personal data may be used for:
    

   1. verifying your identity
       

   2. processing of your request to use our testing and any other related services
       

   3. matching (as defined in the Ordinance) your personal data with other data collected for other purposes and from other sources including third parties in relation to the provision of services
       

   4. marketing and advertising of any services to you by us, related companies, agents, contractors and third party suppliers upon your consent in accordance with the prevailing requirements in the Ordinance
       

   5. prevention, detection or investigation of crime
       

   6. disclosure as permitted or required by law
       

   7. any other purposes as may be agreed to between you and us, including the purposes set out in any application or terms and conditions for the supply of specific services.
       

2. To facilitate the purposes mentioned under paragraphs I(1)(1) and I(2) and for our administrative, research, statistical, marketing, audit and prescribed purposed as permitted by us and the law from time to time, your personal data may be transferred , disclosed , grant access to, shared with, stored, processed or otherwise administered by our group members and/or third party agents, contractors or service providers who provide administrative, telecommunications, computer and other data mining and processing services to us. Such data may be used by other companies under contractual activities with us for the above mentioned purposes. You may object to the above possible uses by giving us a prior notice in the manner set out in “Contact Us” section. After receiving such notice from you, we will cease to use your information in the said manner.
    

3. We shall reveal personal information to any external organization (other than the organization in paragraph III(2) above) only if required by law or with your prior consent. However, your personal data may also be consolidate with other data and used in aggregate form for research and marketing purposes, and in such circumstances individual data shall not be revealed. 
    

4. Your personal data supplied to us such as email addresses may be used for communication and promotion. You may object to the above possible uses by giving us a prior notice in the manner set out in “Contact Us” section. After receiving such notice from you, we will cease to use your information in the said manner.

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IV. DISCLOSURE AND SHARING OF INFORMATION​

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1. Your personal data held by us will be kept confidential by all reasonable steps but we may, where such disclosure or transfer is necessary to satisfy the purpose, or directly related purpose, for which the data was collected provide such information or copies to the following relevant parties:
    

   • member companies within our group
      

   • authorized personnel including contractors, consultants and lawyers for performing various business functions;
      

   • government bodies and other regulators as required under the law or pursuant to any regulatory arrangements between us and the relevant government body or regulator;
      

   • any person under a duty of confidentiality to us and who has undertaken to keep such information confidential, provided that such person has a legitimate right to such information; or
      

   • any person to whom we are required to make disclosure under any law applicable in Hong Kong.
      

2. ​Your personal data may also be disclosed to any person or persons pursuant to any statutory or contractual obligations or as required by court of law, provided such person or persons are able to prove the required right or authority to access such information. In addition, personal data may be disclosed under any of the circumstances described in Part VIII of the Ordinance in which the concerned personal data are exempt from the provisions of Data Protection Principle 3 of the Ordinance.
    

3. In accordance with the requirements of the Ordinance, we will honour a customer’s request not to use his or her personal data for the purposes of direct marketing. Upon customer’s consent, we may use his or her personal data for direct marketing and any other directly related purposes. For the avoidance of doubt, this consent is separate from and independent of customer’s services registered with us. Accordingly it can be withdrawn at any time in the manner specified in “Contact Us” section below without reference to the duration of the services, and will survive the termination or expiration of customer’s service contracts.
    

4. We will do our best to ensure compliance with the Ordinance by providing guidelines to and monitoring compliance of the relevant parties listed above. However, we cannot control how third parties use your personal information and assumes no responsibility for the privacy protection provided by such third parties.

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V. RETENTION OF INFORMATION
 

1. We will destroy any personal data it may hold in accordance with its internal policy. Generally speaking, our policies cover the following principles:
    

   • personal data will only be retained for as long as is necessary to fulfill the original or directly related purposes for which it was collected, in normal circumstances, it will be retained for 7 years, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
      

   • personal data are purged from our electronic, manual and other filing systems in accordance with specific schedules based on the above criteria and our internal procedures.

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VI. INFORMATION SECURITY
 

1. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
    

2. Physical records containing personal data are securely stored area and/or containers when not in use.
    

3. The secure area of the Platform supports the use of e.g. 256-bit Secure Socket Layer (SSL) encryption technology or other industry standards for encryption over the Internet to protect data. When you provide sensitive information, such as credit card details, it will be automatically converted into codes before being securely dispatched over the Internet.
    

4. Furthermore, our web servers are protected behind “firewalls” and our systems are monitored to prevent any unauthorized access.
    

5. Practical steps will be taken to ensure that personal data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements in Hong Kong concerning the retention of personally identifiable information.
    

6. You should, however, be aware that no system is impenetrable and no information provided over the internet can be guaranteed to be completely secure. Therefore we cannot guarantee absolutely the security of any information that you transmit to us or receive from us over the internet.

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VII. TRANSFER OF INFORMATION OUTSIDE OF HONG KONG
 

At times it may be necessary and prudent for us to transfer certain personal data to places outside of Hong Kong in order to carry out the purposes, or directly related purposes, for which the personal data were collected. Where such a transfer is performed, it will be done in compliance with the requirements of the Ordinance.

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VIII. CONTACT US
 

1. Under the Ordinance, individuals have the right to request access to and correction of their personal data. It is also our intention to keep your personal information on our records accurate and up-to-date.
    

2. We could also delete certain personal information held by us should you wish us to do so but this may affect your use of the Platform and/ or our services to you.
    

3. Should you wish to access, correct or delete your personal information held by us or enquire about our privacy policy and practice, please contact us by post or email to:

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Name: Cadmon Lim
Title: Chief Operating Officer
Address: Unit 628, Biotech Centre 2, 11 Science Park West Avenue, Hong Kong Science Park, Shatin, N.T., Hong Kong
Email: cadmon.lim@gemvcare.com