General
- Mobile Medical Services Ltd (“MMS”) is committed to protecting the privacy, confidentiality, and security of the personal data collected by us. And will at all times observe the requirements of the Personal Data (Privacy) Ordinance (Cap.486, Laws of Hong Kong) and other applicable rules and regulations in the collection, use, and maintenance of your personal data. We are equally committed to ensuring that all our employees and agents uphold these obligations.
- This website is owned by Mobile Medical Services Ltd (“MMS”). The terms “the Company”, “we”, “us”, “our” and “ours” when used in these Terms of Use mean Mobile Medical Services Ltd (“MMS”) and its holding company, subsidiaries, affiliate, and related companies. The terms “you”, “your” and “yours” when used in these Terms of Use mean any user of this website.
- This Privacy Policy (“Policy”) explains who we are, how we may collect, use, disclose, process, and manage your personal data, and how you can exercise your privacy rights.
- We reserve the right at any time to amend, update, vary, or add to this Policy from time to time, or any part thereof with or without notice. Any revised Statement will be published on our website(s).
- By accessing or using this website, you agree to be bound by the terms and conditions of this Policy.
- In the event of any discrepancy between the English and Chinese versions of these terms and conditions, the English version shall prevail.
- This Policy is governed by the laws of Hong Kong. You consent to submit to the exclusive jurisdiction of the Courts of Hong Kong in any dispute relating to this Policy.
Applicability of Policy
This Policy is applicable to:- Any user of, or visitor to our websites, platforms, applications, and other online services or products under our control;
- Individuals who share their business contact information and other personal data with us in the framework of a potential or ongoing business relationship or for other business purposes; and
- Any members of the public who interact with us and individuals with whom we do business, including, but not limited to, staff of regulatory authorities and suppliers and visitors to our sites and offices.
Personal Data
“Personal Data” means information which relates to a living individual and can be used to identify that individual. It must also exist in a form which access to or processing of is practicable.- In general, the provision of any personal data to us is entirely voluntary. However, there are circumstances in which we cannot take action without certain personal data, for example, if the personal data is required to process your requests, manage the contractual relationship between us or the company you work for, or provide you with access to specific online content. When the provision of such personal data is mandatory in order for us to provide services to you, we will specifically inform you. Failure to supply personal information requested by us may result in the Company being unable to process your application, request for information or services, inquiries, and/or provide services or products to you if the processing of such personal data is necessary for such purpose(s).
- If you provide the personal data of anyone other than yourself (including your family members, employees – in the case of corporate healthcare arrangements fellow, etc.), you guarantee that you have informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes.
- You confirm that all personal data that you provide to us is true, accurate, and complete.
Personal Data Collection
We may collect your personal data for the purposes as set out in this Privacy Policy.- We collect and/or automatically collect and/or hold your personal data from time to time, including but not limited to the following situations.
- Register for or use any services or products we provide;
- Respond to or register for any of our initiatives or events;
- Visit our website or use our app;
- Send us an email;
- Request to be included in our mailing list;
- Interact with our staff, including customer service officers via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms, and emails;
- Call for an appointment;
- Request us to contact you; and/or
- Submit your personal data to us for any other reason.
- The personal information we collect and/or hold from time to time may include your personal identification information, contact information, transaction records, financial background, medical and health records, biometric data, and your location and activities when you access or browse our website(s) or use our mobile application(s) or portal(s) (including any diagnostic or health-monitoring tools thereon and the Bluetooth and/or wearable device that are used to collect data for the purposes of such tools).
- We will always try to collect your personal data from you throughout the course of your relationship with us and in a range of ways. However, there may be instances where we will need to collect your personal information from third parties or sources in certain circumstances, such as a family member or someone else acting on your behalf, your employers, medical personnel, business/asset acquisition transactions of us, business partners, or public databases.
- If you are under the age of 18, you should obtain consent from your parent or guardian before you provide us with your personal information.
- Storage of personal information may be in various forms including physical (paper) form, digital customer systems or applications, electronic medical record systems, data management software or systems in the usual course of business practices, clinical images taken for diagnostic or treatment purposes on some diagnostic equipment where you have undergone a diagnostic procedure using such equipment at facilities operated by the Company, depending on your engagement with the Company.
Purposes of Personal Data Collection
Your personal data collected automatically may be used, stored, processed, transferred, disclosed, or shared by us for the following purposes from time to time (or where you are our corporate customer, the personal data of your employees) for the following primary purposes):
Primary purposes
- To verify your identity;
- To manage your relationship with us;
- To provide you with the services that you have requested, including but not limited to:
- To assist you with your inquiries;
- To administer medical care, including dispensing medication and treatment;
- To liaise with third-party specialist doctors, clinics, hospitals, and/or medical institutions in relation to your medical care (including by providing them with access to your medical records);
- To contact you for feedback after the provision of our services;
- To personalize your experience at our facilities; and/or
- Purposes that are reasonably related to the aforesaid.
Business purposes
In addition to the purposes set out above, we may also collect, use and/or disclose your personal data for purposes connected or relevant to our business, such as:
- Research for the development of new products and services or improvement of our existing products and services;
- Accounting, risk management, and record keeping;
- Carrying out planning and statistical analysis;
- Processing and handling of medical and insurance claims and payments;
- Staff training;
- Quality assurance of our services;
- In connection with any claims, actions, or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
- Managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
- Conducting any form of investigations including but not limited to those relating to disputes, billing, fraud, offenses, prosecutions, etc.;
- Complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, and conducting audit checks, due diligence, and investigations); and/or
- For purposes which are reasonably related to the aforesaid.
Vendors
- Assessing your organization’s suitability as an external service provider or vendor for us;
- Managing project tenders and quotations, processing orders, or managing the supply of goods and services;
- Creating and maintaining profiles of our service providers and vendors in our system database;
- Processing and payment of vendor invoices and bills;
- Managing our premises and facilities (including but not limited to issuing visitor access passes and facilitating security clearance); and/or
- Purposes which are reasonably related to the aforesaid.
Direct Marketing
- Only with your consent (which includes an indication of no objection), the Company, any members of the Company, and/or the third parties may use/ disclose your personal information collected from time to time, such as providing you with health and beauty-related products and Direct marketing (including via email, SMS, mobile app notifications or instant messaging tools) for offers and promotions of the Services.
- We may not use your personal information for direct marketing purposes unless we have received your consent. For the avoidance of doubt, the latest instruction (for example, consent or indication of no objection, or request for opt-out) received from you shall override any previous instruction given to the Company in this regard in relation to all of your personal information collected or held by the Company from time to time.
- If you choose to personalize your services where such options are available, we will use personal information that we collect so that we can offer you those personalized services or communications. If you do not wish to accept those personalized services or communications, you can unsubscribe from those services at any time and we will cease to offer such services to you.
- You have a choice to withdraw your consent for receiving direct marketing or promotional information/ communications. You may contact us by using the contact details found below. Please be aware that once we receive confirmation that you wish to withdraw your consent for direct marketing, it may take up to [30 calendar days] for your withdrawal to be reflected in our systems. Therefore, you may still receive direct marketing or promotional information/ communication during this period of time. Please note that even if you withdraw your consent for the receipt of direct marketing or promotional materials, we may still contact you for other purposes in relation to the services that you have requested or purchased from us.
When using your personal data to contact you for any of the above purposes, we may contact you via regular mail, fax, e-mail, SMS, telephone, or any other means. In relation to direct marketing, we will only send you such information via regular mail, fax, e-mail, SMS, telephone or any other means where this is permitted under the laws of Hong Kong.
Disclose and Transfer of Personal Data
Personal information collected or held by the Company relating to you will be kept confidential, but the Company may transfer such personal information inside or outside the Hong Kong Special Administrative Region of the People’s Republic of China, for the purposes specified in this Policy to the following parties:
- Any contractor, agent, or service provider which provides administrative, data processing, research, marketing, financial, information technologies, telecommunications, payment, delivery, professional, after-sale, or other services to us, in connection with the purposes specified under this Policy;
- Our service partners to facilitate our services to you;
- Any members of the Company, subsidiaries, affiliates, and related companies and made available to appropriate persons in the Company;
- Any third-party service providers if you opt to use or receive services from them;
- Any governmental, legal, or regulatory authority to which we have a legal duty to provide such data;
- Any actual or proposed assignee, transferee, or successor of or to our rights in respect of your personal data in connection with a merger, sale, or transfer (whether assets or shares); and
- Other parties as notified to you at the time of collection of personal data.
We will only disclose personal information limited to that which is necessary to the above parties for the relevant purposes, who may process (including but not limited to recording, organizing, structuring, storing, adapting, altering, retrieving, using, aligning, combining or erasing) your personal information for the relevant purposes set out in this Policy.
In the event that we complete the acquisition of a new healthcare company or brand, we shall communicate with you through the communication channels you provided to us, and any personal information shall be treated in accordance with this Policy if it is practicable and permissible to do so.
Personal Data Security and Retention
- The Company retains your personal information for as long as necessary for the purposes set out in this Policy, or otherwise agreed between you and us unless otherwise required or permitted under applicable law.
- If the Company no longer requires your personal information for the purposes under this Policy, or otherwise required under law, we will take appropriate steps to securely delete or destroy your personal information or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
- We will take reasonable steps to securely store your personal information. This includes implementing a range of digital and physical security measures. For example, Specific measures we use include regular malware scanning. Your personal data is contained behind secure networks and is only accessible by a limited number of people who have special access rights to such systems as required based on the role and responsibility of such persons and are required to keep the information confidential. We require the same level of diligence from any third party involved in the processing of your personal data in accordance with applicable laws.
Other Website and Use of Cookies
- When you browse our website anonymously, our website will not collect any information from your device unless you intend to provide us with your information.
- Our sites may provide links to other external websites for your convenience. We do not have control over these websites. You are advised to refer to the privacy policies of these websites for more information.
- When you use our sites, we and third-party companies collect information by using cookies and other technologies such as pixel tags (for simplicity we refer to all such technologies as “cookies”). A cookie is a text file containing small amounts of information that a server may download to your computer, mobile, or tablet when you visit a website or use an app. A pixel tag (sometimes called a web beacon) is an invisible image with a line of code that is placed within an email message or on a web page.
- There are different types of cookies that are used for different tasks. These include allowing you to navigate between different pages on a website efficiently, remembering preferences you have given, and helping us identify ways to improve your overall site experience. Others are used to provide advertisements that are more relevant to your interests or to measure the number of site visits and the most popular pages.
- The information we obtain through the use of cookies will generally not contain your personal information. Although we may obtain information about your computer or accessing devices such as domain, IP address, browser type, operating system, etc., this generally does not identify an individual. In certain circumstances, we may collect personal information about you, but only where you voluntarily provide it e.g., by filling out an online inquiry form or on the page of purchasing services from us.
- Most web browsers automatically accept cookies, but you may reject cookies by modifying the browser settings on your computer. Please note that if you choose to decline all the cookies (including those that are strictly necessary), you may be unable to use certain interactive features of our sites.
Data Access and Correction
- You have the rights to:
- Check whether we hold personal information relating to you and access such personal information;
- Ascertain our policies and practices in relation to personal data and to be informed of the kind of personal data held by us;
- Require us to correct any personal information relating to you which is inaccurate;
- Request us to cease using and/or processing your personal information; and
- Change your preference in respect of our use of your personal information.
- All requests for data access or correction shall be made in writing (sent by email) and addressed to:
Mobile Medical Services Limited
Contact Person: Data Protection Officer
Email: marketing@mms-hk.com - We are entitled to charge a reasonable fee for processing your personal data access request.