1. Methods of collection of personally identifiable information
EC Healthcare may collect your personally identifiable information via the following method(s):
- via software applications provided by us, used on or through computers and mobile devices (collectively referred to as “Applications”);
- via social media platforms controlled by us (collectively referred to as “Social Media Platforms”);
- via third parties (e.g. authorized licensors, strategic business partners, landlords and franchisers) and other sources (e.g. public databases, marketing partners and relevant third parties)(collectively referred to as the “Platforms”)
2. Principles of collection of personally identifiable information
EC Healthcare respects the privacy of all individuals that use our Platforms. We endeavor to ensure that all our collection, transmission, storage and usage of personally identifiable information is carried out in compliance with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of the Hong Kong Special Administrative Region (“Hong Kong”)) (hereinafter referred to as the “Ordinance”).
3. Types of personally identifiable information collected
4. Purpose of collection and use of personally identifiable information (including but not limited to)
- identifying you and any accounts you hold with us
- determining and verifying your eligibility for discounts and promotions on our Products and Services
- processing applications or renewal applications for our business partners’ products and services on your behalf
- processing insurance claims for our business partners’ products and services on your behalf
- processing of payment instructions or collection of amounts outstanding from you in relation to the provision of the Products and Services
- enabling us to store your personally identifiable information so as to prevent you from re-entering it each time you purchase and/or renew a Product or Service
- order processing, billing and fulfilment
- direct marketing of our Products and Services (see section headed “6. Direct Marketing” below)
- direct marketing of the products and services of our business partners (see section headed “6. Direct Marketing” below)
- designing services for you
- conducting research, statistical analysis and behavioral analysis
- customer profiling and analyzing your purchasing preferences
- enabling you to participate in the interactive features of our Services, including identifying your friends or individuals, and sharing and communicating with them your shopping experience, when you choose to do so
- making suggestions and recommendations to you and other users of our Products and Services or goods and services that may interest you or them
- customizing our Platforms and its contents to your particular preferences
- provisioning of customer services
- handling your complaints and account enquiries, and handling any claim, action and/or proceedings against our Group or any party
- fraud prevention and detection
- auditing purposes
- making such disclosures as required by applicable laws, rules and regulations
- any other purposes directly related to the purpose for which the personally identifiable information was originally collected
Any questions, comments, suggestions or information other than personally identifiable information that is sent or posted to any part of our Platforms by you will be considered as voluntarily provided to our Group on a no-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 take your personally identifiable information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalising your personally identifiable information). We may use this non-personally identifiable information for, among other purposes, research and analysis to improve our Products and Services.
If necessary, we may transfer your personally identifiable information to places outside of Hong Kong for carrying out the purposes, or the directly related purposes, for which the personally identifiable information is to be collected. All such transfers will be carried out in compliance with the requirements of the Ordinance.
5. With whom may we share your personally identifiable information as collected?
6. Direct Marketing
From time to time, the Group may use your personally identifiable information to send you news, offers, promotions and joint marketing offers and the Group requires your consent for that purpose. We may contact you by email, in-app notifications, social media, SMS, text/picture/video message, telephone or mail. Your name, email address, telephone number, contact address, social media contact, date of birth, Products and Services portfolio information, transaction patterns and behaviors, browsing records, content viewing habits and personal interests held by the Group may be used by the Group in direct marketing of our Products and Services and products and services offered by our business partners, including without limitation beauty, skincare and cosmetic products and services, which may be of interest to you.
You may decide to “opt in” to, or to “opt out” from, use by us of your personally identifiable information for promotional and marketing purposes. If you prefer not to receive any direct marketing communications from us, you can opt out at any time by updating your preferences through your registered account or an unsubscribed link as provided by us. You can also write to us or send us an email at the addresses as listed in section 4 above. Any such request shall state clearly the relevant personally identifiable information that you would like to opt out for. Upon receipt of the request, we shall cease to use your personally identifiable information for the purpose of direct marketing as soon as possible without extra charges.
- recognize you whenever you visit the Websites
- 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 Products and Services and to help us better understand our visitor and customer requirements and interests
- target our marketing and advertising campaigns and those of our business partners and advertisers more effectively by providing interest-based advertisements that are personalised to your interests
- make your online experience more efficient and enjoyable
- enable tighter security
8. Security measures taken to safeguard your personally identifiable information
The security and confidentially of your personally identifiable information is extremely important to us. We have implemented technical, administrative, and all reasonable and practicable measures to protect your personally identifiable information from any unauthorized access and improper use. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware that despite our best efforts, no security measures are perfect or impenetrable.
9. Retention of your personally identifiable information
We will not keep your personally identifiable information longer than is necessary for the fulfillment of the purpose (including any directly related purpose) for which the information is or is to be used. This means that, for example, personally identifiable information collected to fulfill your request for Products and Services will be erased, deleted, destroyed or anonymized after their delivery by using technical or other means to render such information unidentifiable or unusable, unless it is necessary to keep such information for other purposes and we have informed you of such other purposes at the time of collection of the personally identifiable information or obtained your consent.
Our Group reserves the right to charge you a reasonable fee for complying with a data access request as permitted by the Ordinance.
Date of Last Revision: 02 Feb 2021
List of Potential Transferees of Personally Identifiable Information
Parties to whom personal identifiable information collected by us may be transferred:
- Governments, law enforcement authorities, courts and tribunals.
- Legal and other professional advisors, insurers, loss adjustors, rehabilitation service providers.
- Any third party whom you have authorized to obtain your personally identifiable information from the Group, including without limitation agents, contractors or third party service providers who provide Products and/or Services to us or have any form of business partnership with us.