Bowtie x JP Partners Medical Centre Limited ("we", "our" or "us") consider the privacy of our patients, users of our services, visitors of our facilities and clinic(s), and visitors and users of our website (https://www.bowtiejphealth.com/), applications and other platforms ("you" or "your") is of utmost importance. This statement establishes how we collect personal data from your use of our services, participation in our clinical diagnostic procedures, visit of our facilities and clinic(s), and visit and use of our website, applications and other platforms and how we use or disclose such personal data.
We are committed to protecting the privacy, confidentiality and security of personal data we collect and hold by complying with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"). Please visit the website of the Office of the Privacy Commissioner for Personal Data, Hong Kong at http://www.pcpd.org.hk for more information on the PDPO and relevant guidance notes.
Types of Personal Data Collected and Held by us
We may obtain from (I) you; (II) third parties authorised by you; (III) our clinical diagnostic procedures; (IV) your correspondence with us; and (V) your use of our facilities, clinic(s), website, applications, and other platforms, your data and information about you including your personal data, and hold such data and information. Such data and information includes, but is not limited to, the following:
- your personal particulars;
- your contact information (including correspondence address, telephone number, email address and preferred language for communication);
- personal particulars and contact information of your emergency contact person(s) and/or next-of-kin(s);
- your credit or debit card account details and billing information (including the name of the cardholder, credit or debit card number and expiry date);
- your insurance information (including the name of the insurer or broker, insurance policy number and insurance coverage);
- your medical history / condition, drug history and/or other relevant information relating to your health;
- information that you provide to us by filling in the blanks on our website, applications and other platforms;
- your feedback of the products or services; and
- details of your visits to our website, applications or other platforms, including, but not limited to, traffic data, location data, blogs and other communication data.
- We may generate and compile additional personal data using the above and other information and particulars about you.
- We may retain a record of the correspondence if you contact us.
Use of Personal Data
Your personal data may be used mainly for the following purposes and / or any purposes directly relating to any of them:
purposes relating to your healthcare and / or generally for medical care or treatment purposes, including but not limited to the following:
- verification of your identity;
- arrangement and/or provision of healthcare services, medical treatments, and/or facilities, medication and related products (collectively "Services") to you;
- communication with you in relation to arrangement / provision of Services; and
- processing of payment and/or insurance claims and/or collection of amount(s) due from you;
- teaching, education, research and/or statistical purposes by us or any other company which is our subsidiary or holding company or is a fellow subsidiary of such holding company (each an "Affiliate" and collectively the "Affiliates");
- operation, usage statistics analysis, improvement, and maintenance of our and our Affiliate’s information systems and our and our Affiliate’s website, applications and platforms for patients, doctors and other healthcare providers;
- provision of our and/or our Affiliates’ promotional and direct marketing materials to you pursuant to paragraph 4 below;
- evaluation, planning and improvement of services which we and/or our Affiliates provide;
- communication between you and us or our Affiliates;
- our or our Affiliates' accreditation, audit, service quality control and administrative purposes;
- processing, assessing and determining any applications or requests made by you in connection with our services or products;
- managing and maintaining your account;
- facilitating third party providers and our Affiliates to contact you and provide assistance to you provided that you have expressed interest in their products or services;
- investigation and processing of complaints or disputes;
- prevention or detection of crime;
- compliance with or disclosure as permitted or required by any law, rule, regulation, code or guideline (collectively "Law");
- analyzing our website (www.bowtiejphealth.com), applications and other platforms' usage statistics for the purpose of managing and improving their design and functionalities;
- provision of after-sales services; and
- any other purposes as may be agreed between you and us, including purposes set out in any written communication or terms and conditions for the supply of specific services/facilities to you by us.
- When we collect personal data from you, we will provide you with a personal information collection statement ("PICS") in an appropriate format and manner (such as the Personal Information Collection Statement to Patients) to identify to you the purposes for which your personal data are collected and the types of third parties to whom we may disclose your personal data. It is voluntary for you to provide your personal data to us. However, if you fail to do so, we may not be able to serve the purposes listed above.
Transfer and Disclosure of Personal Data
- We will keep your personal data confidential but we may, in addition to our staff, transfer or disclose your personal data to third parties (such as your attending doctors/healthcare providers, your insurer, our Affiliates, our agents and service providers or such other persons as permitted by any Law and whether within or outside Hong Kong) for the purpose(s) as set out in the relevant PICS. We will also disclose your personal data as required by any Law.
- We may transfer or assign the personal data you provided to us in the event of a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of winding up of us.
- We may transfer or store your personal data at a place outside Hong Kong. It may also be processed by staff working inside or outside Hong Kong, who work for us, our suppliers or our Affiliates. These staff may be engaged in, including but not limited to, the fulfillment of activities contemplated in and/or ancillary to paragraph 2 above, the processing of your payment and provision of after-sales services.
- Except as stated in paragraphs 3.1 to 3.3 above, we will not transfer or disclose your personal data to any third party without your prior consent.
- By virtue of the PDPO, we will not use your personal data for direct marketing purposes without your prior consent.
- Upon receiving your consent, we may use your personal data such as your name, mobile phone number and email address to provide you with promotional and direct marketing materials in relation to healthcare services provided by us or our Affiliates through various communication channels such as SMS and email.
- If you do not wish to receive direct marketing materials from us, you may send your request to opt out at any time to email@example.com or through such other channels as we may announce from time to time.
Retention of Personal Data
- We will not keep your personal data for longer than is necessary for fulfilling the purposes (including any directly related purposes) for which they are, or are to be, used. Different retention periods apply to different types of personal data collected and held by us in accordance with our retention policies.
Accuracy and Security of Personal Data
- We have appropriate procedures in place to maintain, so far as is reasonably practicable, the accuracy, completeness and relevance of the personal data used by us in relation to the purposes for which the personal data are collected.
- We take appropriate steps to protect the personal data we hold against unauthorized or accidental access, processing, erasure, loss or use.
- We have provided relevant training to our employees to handle personal data properly and apply encryption to personal data as necessary and appropriate. Although we may allow you to adjust your privacy settings to limit access to your information, no security measures are perfect or impenetrable. We cannot control the actions of other users or third parties with whom you may choose to share your information. Therefore, we cannot and do not guarantee that the personal data you provide to us will not be viewed by unauthorized persons.
- We are not responsible for circumvention of any privacy settings or security measures contained on our website by unauthorized users.
- Even after removal, copies of information that you have provided to us may remain viewable in cached and archived pages or if other users have copied or stored such information.
- Where you have chosen, or we have given you, a password to access certain components of our website, you are responsible for keeping such password confidential. We ask you not to share such password with anyone. We also exclude all liabilities in case you lose such password.
The information collected by means of cookies on our website about you will be used only for the following purposes:
- facilitate us in providing a good experience when you browse our website and also allows us to gain insights on how we can further improve our website;
- provide you with a more personalized experience on our website;
- remember you when you revisit our website;
- study browsing behaviors on our website; and
- obtain information regarding the number of visitors to our website and the pages viewed.
Access and Correction of Personal Data
- You have the right to request access to and/or correction of your personal data held by us. You can make your data access and/or correction request in writing to our Data Protection Officer by post to Shop B, Ground Floor, China Hong Kong Tower, 8-12 Hennessy Road, Wan Chai, Hong Kong or email to firstname.lastname@example.org .
- We will require you or any other person who makes such a request on your behalf to provide suitable documents or information for verification of identity and/or confirmation of authorization.
- For any data access request, you may direct such request to us at the contact stated at subparagraph 8.1 above or use the form specified by the Privacy Commissioner for Personal Data.
- Any data access request is subject to payment of a reasonable fee.
- If you have any enquiries on this statement or wish to obtain further information on our privacy policies and practices, please write to email@example.com.
- If there is any inconsistency or conflict between the English and Chinese versions of this statement, the English version shall prevail.