Personal Data Privacy Policy

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Personal Data Privacy Policy

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

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