1. Personal
Data Privacy
UMP Healthcare Holdings Limited and its
subsidiaries (collectively, “UMP”, “we”, “our” or “us”) are committed to
protecting your privacy and will at all times observe the requirements of the
Personal Data (Privacy) Ordinance (Cap.486, Laws of Hong Kong) in the
collection, use and maintenance of your personally identifiable information
(“Personal Data”).
2. Collection
of your Personal Data
We may collect, use and hold a range of
different Personal Data about you. For the purposes of carrying on our business
on any UMP platform which includes the provision of medical and healthcare
services by medical practitioners to eligible users (including the verification
of your identity, the registration, activation and management of your account
with us, and billing and charging (collectively, "Service(s)")) and
compliance with laws, rules, guidelines, regulations and/or requests issued by
applicable government authorities, courts, law enforcement or other authorities
or regulatory bodies, you may be requested to provide Personal Data including
but not limited to:
(a) the
name, date of birth and other details documented on your identification
document (e.g. Hong Kong identity card and passport);
(b) contact
details, including name, address, phone number, mobile telephone number and
email address;
(c) health
information, including medical concerns, self-reported symptoms, existing
medications, allergies and diagnosis;
(d) messages
exchanges between you and UMP customer service staff;
(e) insurance
information;
(f) credit
card information; and
(g) any
other Personal Data as may be reasonably required by UMP and/or its respective
contractors, sub-contractors, agents, representatives, business partners or
representatives, Service providers, healthcare providers, healthcare
professionals (including medical practitioners/ doctors, nurses, pharmacists
and other medical staff) from time to time and which is necessary for the
provision of the Services and/ or for your access to medical consultation and
prescription services provided by healthcare providers and/or healthcare
professionals through UMP platform.
3. How
we collect Personal Data
3.1 You
directly, for example, when you provide Personal Data by submitting your
Personal Data through our websites, UMP application, or over any customer
service hotlines or UMP chat sessions; or when you contact us with a query or
request;
3.2 Third
parties such as related entities, healthcare providers, healthcare
professionals, business partners, or other customers, or your representatives
with appropriate consent from you if required;
3.3 Your
visits to our websites, or mobile apps; and/or
3.4 Your
participation in surveys or marketing promotions organized by us or on our
behalf.
4. Purposes
for which Personal Data are Collected and Used
The purposes for which your Personal Data
are collected and used may include (without limitation) one or more of the
following purposes:
4.1 For
the supply of any Services, products, facilities and/or other subjects which we
or any of our subsidiaries, holding companies, joint ventures and associated
companies may offer to you, or you may require from us, from time to time;
4.2 For
payment purpose for any of the Service, including verification of credit card
details or insured identity with third parties;
4.3 For
use of the online Services available at any of the websites of UMP and/or
through other telecommunication channels;
4.4 With
your consent, for marketing or promoting any of the Services (e.g. sending you
updates on our latest offers and promotions in relation to any of our Services
from time to time);
4.5 With
your consent, form promoting and soliciting donations or contributions for
charitable or nonprofit making causes;
4.6 For
identification and verification purposes in connection with any of the Service
that may be supplied to you;
4.7 For
reservations with or through us or any member of UMP;
4.8 For
communicating with you by email, mail, fax, phone or other means, including
contacting you regarding your enquiries;
4.9 For
conducting research and/or analysis from time to time to better understand your
shopping, dining, spending and/or other consumption needs, preferences,
interests, experiences and/or habits;
4.10
For designing and administering new and/or enhancing existing Services,
activities, contents and/or other events;
4.11
For managing customer relationship and relationship with UMP’s
suppliers;
4.12
For making disclosures when required by law, regulation, or court order
of any jurisdiction and/or as represented by any government, regulatory or law
enforcement authority or administrative organization, which may be within or
outside The Hong Kong Special Administrative Region of the People’s Republic of
China (“Hong Kong”);
4.13
For establishing legal claims or defences, obtaining legal advice,
and/or exercising, defending and/or protecting the rights or properties of the
members of UMP;
4.14
For the use by any member of UMP in connection with any of the above
purposes and/or any of the Services that any member of UMP may offer or supply
to you from time to time; and/or
4.15
For any other incidental or associated purposes relating to the above,
or any other purposes as specified in a personal information collection
statement when your Personal Data is being collected, or any other purposes
which you may from time to time agree.
We will not knowingly or intentionally use,
share or sell your Personal Data in ways which are unrelated to the above
purposes (or purposes as specified in a personal information collection
statement when we collect your Personal Data) without your prior consent.
5. Use
of Cookies
5.1 If
you visit any of our websites, we may use cookie files to store and track
information about you and your preferences. A cookie is a small text file that
our website transfers to your computer's or device's hard disk. We use cookies
to better serve you and/or maintain your information across multiple pages
within or across one or more sessions. Most web browsers automatically accept
cookies, but if you prefer, you can edit your browser options to block them in
the future. However, if you disable cookies or refuse to accept a request to
place a cookie, certain functionalities on our websites may not be available.
5.2 We
may also collect information regarding your IP address, browser type, domain
name and access time. This information is used for our own research purposes.
As it is not linked to any personal information, it is separate from your
Personal Data. In rare instances, IP addresses may be used to assist in
deterring and/or preventing abusive or criminal activity on the website.
6. Children's
Privacy
Protecting the privacy of children is our
primary concern. Hence, we will not knowingly collect or maintain Personal Data
in our database from persons who are under 18 years of age without consent from
a parent or guardian.
7. Retention
of Personal Data
We will retain your Personal Data in
accordance with applicable laws and regulations. Subject to all applicable laws
and regulations, our retention covers the following principles:
(a) Personal
Data will only be retained for as long as is necessary to fulfil the original
or directly related purposes for which it was collected, unless the Personal
Data is also retained to satisfy any applicable legal, regulatory or
contractual obligations; and
(b) Personal
Data are purged from our electronic, manual and other filing systems based on
the above criteria and our internal procedures.
8. Disclosure
and Transfer of Personal Data
8.1 We
will keep your Personal Data confidential and will not disclose or transfer
your Personal Data to any third party without your consent, except as required
by laws. However, your Personal Data might be disclosed or transferred to any
third parties where such disclosure or transfer (as the case may be) is
necessary to satisfy the purpose(s) for which the data were collected.
8.2 To
provide our products and Services, we may transfer, disclose, grant access to
or share your Personal Data with third parties located within or outside Hong
Kong, and your Personal Data may be transferred within or outside Hong Kong.
These third parties will process your Personal Data similar to UMP and they may
include:
(a) any
agent, contractor or third-party service provider who provides administrative,
marketing, research, distribution, data processing, telemarketing,
telecommunications, computer, payment or other services to or support the
operation of UMP’s business (including its/their direct marketing activities);
(b) any
person under a duty of confidentiality to any member of UMP (including
accountants, legal advisers or other advisers);
(c) any
actual or proposed assignee or purchaser of all or any part of the business
and/or asset of UMP;
(d) insurance
companies that have business dealings with UMP;
(e) any
regulators, law enforcement or other agencies, and any other self-regulatory or
industry organizations or associations whose orders are legally binding to UMP;
(f) third
party awards, clients or members, branding cooperation and concession program
suppliers;
(g) an
officer authorized of your affiliated company; and
(h) the
following persons for the purpose specified in Section 4 of this Policy:
adjusters, agents and brokerage; employers; health care professionals;
hospitals; accountants; attorneys; agencies integrating insurance claims and
underwriters; fraud prevention organizations; insurance companies (either
directly or through fraud prevention organizations or others named in this
paragraph).
9. Links
to Other Websites
In anticipation of your needs, our websites
may contain links to third-party sites that are operated under different
privacy practices. All such websites are independent from our websites. We have
no control over the contents of such other websites or their privacy policies
or compliance with the law. You should, therefore, be fully aware the provision
of such links does not constitute an endorsement, approval, or any form of
association by or with UMP. We have no control over Personal Data that is submitted
to these other websites. You should remain alert when you leave our websites,
and read the privacy statements of other websites.
10. Security
10.1
We will take all reasonable steps to ensure that your Personal Data will
not be subject to unauthorized access. In particular, access to your Personal
Data will only be restricted to personnel who have a need to use the data and
who have been trained to handle such data properly and observe confidentiality.
10.2
When we pass your Personal Data to third-party organizations for them to
process, we seek to ensure that they have appropriate security measures in
place to keep your Personal Data safe and to comply with applicable principles
in relation to data protection. Some of the people we share your Personal Data
with may process it overseas. You can contact us for more information about the
safeguards we use to ensure that your Personal Data is adequately protected in
these circumstances.
10.3
Encryption technology may also be employed for the transmission of
Personal Data collected on this website.
11. Direct
Marketing
11.1
If we intend to use, or otherwise provide to third party, your Personal
Data (including your name and contact details) collected from you for direct
marketing purposes (e.g. to send you marketing communication about news, offers
or promotions in relation to the Services of UMP), we will first obtain your
consent (or an indication of no objection) before doing so.
11.2
If you agree to receive marketing communications but do not wish to
receive them in the future, you may opt out of receiving them at any time, free
of charge, by the following applicable means:
(a) unsubscribing
by following the “Reply to” instructions contained in the marketing text
message;
(b) following
the unsubscribe instructions or hyperlink in the message;
(c) following
the unsubscribe instructions in mobile applications;
(d) notifying
us that you no longer wish to receive marketing communications when receiving
our marketing calls; or
(e) contacting
us in writing by post or by email at the address or email address stated herein
in clause 13 below to tell us that you no longer wish to receive marketing
communication.
11.3
We may issue service-related announcement to you when necessary (e.g.
when we suspend a Service for system maintenance). You may not be able to opt
out of these announcements which are service-related and not promotional in
nature.
12. Your Right to Access and Correct
12.1
We take all reasonable precautions to ensure that the Personal Data we
collect, use and disclose is accurate, complete and up-to-date. However, the
accuracy of that Personal Data largely depends on the Personal Data you
provide. You have a right to request access to, and correction of, your
Personal Data and we recommend that you:
(a) let
us know if there are any errors in your Personal Data; and
(b) keep
us up-to-date with changes to your Personal Data.
12.2
If you wish to access or amend any of your Personal Data we hold, you
may contact us in the manner as set forth under the “Contact Us” section.
12.3
You may also exercise your right of access and correction by logging on
to UMP app where you will be able to view and correct some of the Personal Data
held by us about you.
12.4
You may decline to share Personal Data with us, in which case, we may
not be able to provide you with some of our Services.
13. Contact
Us
You have the right to request access to and
correction of your Personal Data held by us.
To request access to or correction of your
Personal Data or if you have any inquiries relating to this Policy and our data
practices, please contact us using one of the following methods:
13.1
mail your request or inquiry to:
UMP Professional Management Limited
27/F Wing On House, 71 Des Voeux Road Central, Hong Kong
13.2
email your request or inquiry to dataprotectionofficer@ump.com.hk
14. Note
This Policy may be amended from time to
time. You may access and obtain a copy of this Policy, as amended from time to
time, at www.ump.com.hk so that you are always informed of the way we collect
and use Personal Data.
This Policy is written in English language
and translated into Chinese language. In event of any inconsistency between the
English version and the translated version of this policy, the English version
shall prevail.
Updated: March 2024