Pedder Health and our associated companies (together, “Pedder” or “us”) are committed to protecting the privacy of personal data of every customer (the “Customer” or “you”) who uses our services (the “Services”) in compliance with the requirements of the Personal Data (Privacy) Ordinance (the “Ordinance”) and all related codes of practice and guidance notes issued by the Privacy Commissioner for Personal Data.

Please read the following carefully to understand Pedder’s policy. This policy may from time to time be revised or changed as we deem necessary.

Types of personal data collected

Pedder may collect your personal data, including but not limited to the following:

• Full Name;
• Correspondence Address;
• Contact phone number;
• Hong Kong Identity Card No. or travel document number;
• Date of Birth;
• Gender;
• Medical Records and History;
• Bank account information (if applicable)
• Credit card information (if applicable); and
• Information about your insurance plan and coverage (if applicable)

Purposes of collection

Your personal data may be used for the following purposes or any connected purposes by Pedder (“Purposes”):

• identity verification;
• provision of the Services to you;
• matching your personal data with other data collected for other connected purposes and/or from other sources including third parties in relation to the provision of the Services to you;
• processing of any benefits in connection with the provision of the Services to you;
• analysing, verifying and enforcing contractual rights in relation to the supply of the Services to you;
• enabling the operation of your customer financial account, the checking of your credit, payment and/or the processing of any payment instructions, autopay facilities and/or credit facilities in relation to supply of the Services to you, or requested by you;
• enabling the collection of amounts outstanding in your customer financial account in relation to the provision of the Services to you, including the use of debt collection agents;
• enabling us to engage and communicate with the classes of transferees listed below in relation to the supply of the Services to you;
• keeping you informed about the Services supplied to you and other goods and services made available to you;
• business planning and improving the Services provided to you;
• disclosure as permitted or required by law; and/or
• any other purposes as may be agreed between you and Pedder.

Classes of transferees

Except with your prior consent, we will not transfer or disclose the personal data collected to any third party except as stated below:

• the Electronic Health Record Office under the Food and Health Bureau of the Government of the Hong Kong Special Administrative Region, pursuant to the requirements under the Electronic Health Record Sharing System Ordinance;
• any of our personnel, affiliates, related parties, agents, auditors, contractors and/or third-party suppliers (as applicable) engaged by us to provide services or advice in connection with our operations; and
• any person to whom we are permitted or required to make disclosure to under any law or court order applicable in Hong Kong, or as requested by any government or law enforcement authority or agency.

Personal data security

Pedder takes appropriate steps to protect the personal data we hold against loss, unauthorized access, use, modification or disclosure.

Personal data retention

Pedder strives to ensure that personal data is not kept longer than is necessary for the fulfilment of the Purposes for which the data is or is to be used. Different retention periods apply to the various kinds of personal data collected and held by Pedder. Personal data which is no longer required will be destroyed.

Personal data disclosure

Your personal data is used only for Purposes directly related to our services, functions and activities. Other than the classes of transferees listed above, Pedder will not transfer your personal data to any unauthorized parties without your prior consent.

Access to or correction of personal data

Should you wish to access or make corrections to your personal data, you may do so under the Ordinance by sending your written request marked “Confidential” to our Personal Data Privacy Officer to one of the following addresses:

After we have received a data access or correction request, our staff will verify the identity of the requester to ensure that he/she is a person legally entitled to make the data access or correction request. A fee will be charged for complying with a data access request but no charge will be levied for a correction request.

Enquiries

Enquiries can be directed via mail to the address as indicated above.

Last updated: September 5, 2019