Total HealthCare (A member of Hong Kong Ferry (Holdings) Company Limited (SEHK:0050) ) refers to Total HealthCare and Hong Kong Ferry (Holdings) Co., Ltd. and its brands, subsidiaries, and affiliated entities (hereinafter collectively referred to as “we”, “us”, “our”, “Group” or “Total HealthCare”). A list of the brands, subsidiaries, and affiliated entities can be found on our website: https://totalhealthcarepain.com/ and https://www.hkf.com . This Privacy Policy applies to all personal data that we may obtain from the following parties: (i) current customers; (ii) potential customers who provide personal data to us while indicating their interest in our services and products (hereinafter collectively referred to as “Services and Products”, and individually as “Services” and “Products”); and (iii) third parties who provide us with such Services and Products. This Privacy Policy does not apply to any personal data that is obtained by us for recruitment or employment purposes.

Please read this Privacy Policy carefully to understand the policy and practices of our Group regarding how we are committed to safeguarding your privacy and ensuring that your Personal Data is protected.

This Privacy Policy may from time to time be revised, or otherwise changed as the Group deems necessary but the Group will endeavour to give you the advance notice of any such revision or change where practicable.

1. Your Privacy

We respect the personal data privacy of all individuals and pledge to be in compliance with the requirements of the Personal Data (Privacy) Ordinance of Hong Kong (“PDPO”) so that the privacy of your personal data is protected in accordance with the standard required by law. In doing so, we require all our staff to comply with the PDPO in the same manner as the PDPO applies to us as a whole and adhere to the strictest standards of security and confidentiality.

“Personal Data” is information that relates to an identified or identifiable individual. We may collect your information in the following categories:

Information about you:

your name, gender, age, date of birth, HKID card/identification document number, phone number, fax number, residential address, corresponding address, email address, signature, biometrics data, and biomedical specimens;

Information to process your order or use of our Services and/or Products:

credit card information, bio-medical data, medical records, medical reports, medical images, and medical photos;

Information relating to your associated organisation, friend(s), or family member(s):

the name of the organisation, title in the organisation, your staff/membership number of such organisation, the name of your friend(s) or family member(s), your relationship with the friend(s) or family member(s), their HKID card/identification document number(s), and their signature;

Information collected when visiting our online platforms including websites, mobile applications, social media platforms and/or any online communication between you and us (see section 6. Use of Cookies below)

IP address, browser settings, browsing records, and/or other Internet log information;

Additional information you may wish to provide us with:

2. How do we collect and store your Personal Data

Total HealthCare may collect your Personal Data via the following methods:

directly from you when you submit our membership registration/application;

directly from you when you submit Personal Data to indicate your interest in or when purchasing our Services and Products via our websites, mobile applications, social media platforms, and any online or face-to-face communication between you and us;

You will also be required to supply Total HealthCare with Personal Data from time to time throughout your use of Services and Products provided by us. All Personal Data collected will be stored within the Total HealthCare personal data system.

3. Purposes for which your Personal Data will be used

The purposes for which your Personal Data may be used are as follows:

to determine and verify your eligibility for registering for our membership and using our Services and Products;

to enable us to store your Personal Data and identify possible multiple applications and obtain records of your use of our Services and Products across the Group from time to time;

to identify you and any accounts you hold with us on behalf of your family members and/or friends;

to enable the provision of our Services and Products to you, including customer services such as handling complaints and account inquiries, order processing, appointment arrangement, processing of insurance claims, and processing of payment instructions or collection of amounts outstanding from you in relation to the provision of our Services and Products, medical testing and diagnosis, laboratory services including testing services etc.;

as fraud prevention and detection;

for auditing purposes;

to make such disclosures as required by applicable laws, rules, and regulations; and for all other purposes ancillary to the above purposes.

Any questions, comments, suggestions, or information other than your Personal Data that is sent or posted to any part of our Platforms by you will be considered as voluntarily provided to our Group on a non-confidential and non-proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish and/or post elsewhere such information freely, including passing it to any associated company for example, in connection with the development and marketing of services and to meet user needs.

We may also take your Personal Data and make it unidentifiable, either by combining it with information of other individuals or by removing any identifiable information from your Personal Data (such as your name) for, among other purposes, research and analysis to improve our provision of Services and Products.

Unless otherwise indicated, it is obligatory to supply the requested Personal Data. Failure to provide the requested Personal Data may result in us not being able to process your application or provide you with the necessary support during your use of our Services and Products.

If necessary, we may transfer your Personal Data to places outside of Hong Kong for carrying out the purposes, or for the directly related purposes, for which the Personal Data is to be collected. All such transfers will be carried out in compliance with the requirements of the Ordinance.

Furthermore, subject to relevant laws, rules and regulations, we may from time to time use your Personal Data collected through the Group’s various systems/platforms and other interactions with you in direct marketing (see section 5. Direct Marketing below).

4. Disclosure

All Personal Data will be kept confidential but we may disclose such information to third parties where such disclosure is necessary to fulfill one or more of the purposes as described in section 3 hereinabove. A list of classes of persons (who may be located within or outside of Hong Kong) to whom your Personal Data may be transferred can be found in the List of Potential Transferees of Personal Data as stated below.

Total HealthCare and Hong Kong Ferry (Holdings) Co., Ltd. and any of its brands, subsidiaries and affiliates; (a list of the brands, subsidiaries, and affiliated entities can be found on our website: https://totalhealthcarepain.com/ and https://www.hkf.com )

Governments, law enforcement authorities, courts, and tribunals;

Legal and other professional advisors, insurers, loss adjustors, and rehabilitation service providers;

Any third party whom you have authorised to obtain your Personal Data from the Group.

Furthermore, we may, from time to time, purchase or sell one or more of our businesses (or portion thereof) and your Personal Data may be transferred as part of the purchase or sale. In the event that we have completed the process of purchasing of a business unit, we shall communicate with you through the communication channels you provided to us, and any Personal Data we obtained following your consent shall be treated in accordance with this Privacy Policy if it is practicable and permissible to do so.

5. Direct Marketing

From time to time, the Group may use your Personal Data to send you news, offers, promotions, and joint marketing offers and the Group must obtain your consent for the purposes mentioned hereinabove.

The types of direct marketing activities Total HealthCare and its affiliated companies may conduct using your Personal Data include providing you with information and details in connection with the latest news, events, updates, discounts, promotions.

Total HealthCare and its affiliated companies will do this through various communication channels such as direct mail, email, telephone, SMS, mobile applications notifications, social media, and text/ picture/ video messages by using your Personal Data held by the Group. We will not use your Personal Data in direct marketing without your consent.

If you wish to opt-out of direct marketing from Total HealthCare and its affiliated companies anytime in the future, please send your English full name and membership number to [email protected] indicating that you wish to opt-out from Total HealthCare using your Personal Data in direct marketing. Upon receipt of the request, we shall cease to use your Personal Data for the purpose of direct marketing as soon as practicable without extra charges.

6. Use of Cookies

Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit or access our Websites and/or applications. We use cookies on such Platforms to:

recognise you whenever you visit our Websites and/or mobile applications;

obtain information about your preferences, viewing and browsing behaviour, online movements, and use of the Internet;

keep track of the items stored in your account and take you through the checkout process;

carry out research and statistical analysis to help improve our Services and Products and to help us better understand our visitor and customer requirements and interests;

make your online experience more efficient and enjoyable; and enable tighter security.

The information we obtain from our use of cookies may not contain your Personal Data. Although we may obtain information about your computer or other electronic devices such as IP address, browser settings, browsing records, and/or other Internet log information, this may not be able to identify you personally. To the extent that such non-identifiable data is combined with your Personal Data, we treat the combined information as Personal Data for the purposes of this Privacy Policy.

If you want to disallow the use of cookies, you can do so on your own web browser or electronic devices. If you disable cookies, you acknowledge that you may not be able to use some of the functionality of our Websites and/or Applications.

7. Amendment(s) to this Privacy Policy

We may from time to time amend this Privacy Policy to reflect new technologies, regulatory requirements, or any changes that may be necessary. We will notify you of any updates in accordance with your preference settings and, where required by law, obtain your consent. We may notify you of such changes by sending you an email at the latest email address that you provided to us, and/or by prominently posting notice of such changes on our Website at https://totalhealthcarepain.com/

8. Correction

You may correct your Personal Data in the records of Total HealthCare’s personal data system, and a fee may be required by us for processing your request.

Pease write to us at 98 Tam Kon Shan Road, Ngau Kok Wan, North Tsing Yi, New Territories, Hong Kong or send us an email at [email protected].

9. Minors

If you are under the age of 18, you should obtain consent from your parent or guardian before you provide Total HealthCare with your personal data.

In the event of any discrepancy or inconsistency between the English and Chinese versions of this Privacy Policy, the English version shall prevail.

Date of Last Revision: 16 April 2024