Privacy Policy Statement of "My Gleneagles SmartHealth"

1. Gleneagles Hospital Hong Kong ("Gleneagles ") is committed to complying with the data protection principles and the relevant provisions of the Personal Data (Privacy) Ordinance ("the Ordinance") of the laws of Hong Kong SAR.  Before you furnish any personal information to Gleneagles, please read the following before you do so.  You may also refer to the Personal Data Protection Notice of our parent company IHH Healthcare Berhad.

2. Gleneagles developed My SmartHealth mobile application ("Mobile App") for users to access and manage patient-related information via mobile device.  The purposes for which the personal information is being collected will be identified before or at the time of collection.

3. You may need to register for an account in order to use some of the services in the Mobile App.  You need to provide personal information to Gleneagles which may include name, the identity document information, date of birth and contact information.

4. When you provide your personal information, please make sure that the data is accurate and complete. If you fail to provide us with the information required or if the information provided is inaccurate or incomplete, our consideration of your registration will be affected and may become unsuccessful.

5. All personal information will be used solely for the purpose for which it was gathered, for purposes directly related, or to assist you in making enquiries or appointments, or for other compatible purposes, or any other purposes as may be agreed between you and Gleneagles, including clinical research and development, clinical teaching and professional training carried out by Gleneagles jointly with The University of Hong Kong unless Gleneagles obtains the consent of the individual concerned or as required by law or court order. The purposes included but not limited to:

a. Identifying and verifying your identity and/or as an account user; 

b. Registering you as a user of the Mobile App; 

c. Following registration as a user, accessing your account information and managing your account (including but not limited to changing your password, updating your personal information, etc.); 

d. For you to make enquiries, complaints, and/or suggestions to us in relation to the services of Gleneagles; 

e. Improving the Mobile App, the services provided by Gleneagles and any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by Gleneagles (“the Related Companies”); 

f. Direct marketing from Gleneagles or the Related Companies; 

g. Data analytics, information management and database administration; 

h. Deterring, detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our policies or may be abusive, illegal and/or criminal; 

i. Collection or recovery of any debt owed by you to Gleneagles; 

j. The normal management, operation, and maintenance of the Mobile App and the provision of services to you; and/or 

k. Storing your personal information for the purpose of sharing such personal information with the Related Companies.

6. For certain functionalities, Gleneagles requests your permission to collect, use and/or access: 

a. The camera or photo album on your mobile device for the account profile photo; 

b. The calendar on your mobile device for recording your appointments;

You may provide and/or withdraw your permissions to the collection, use and/or access of the aforesaid personal information by the Mobile App.

7. Gleneagles will record visits to the Mobile App without collecting any personal identifiable information from users. Such general statistics are collected to compile statistical reports and diagnose problems with, or concerning, computer systems to help Gleneagles improve the Mobile App.

8. All personal information held by us will be kept confidential but Gleneagles may, where such disclosure is necessary to satisfy the purpose for which the data was collected, provide such information to: 

a. the Related Companies; 

b. Any person or company who is acting for or on behalf of Gleneagles, or jointly with Gleneagles, including medical staff, doctors, consultants, nurses, secondees and student trainees of The University of Hong Kong, in respect of the purpose for which the personal information was provided; 

c. Any other person or company who is under a duty of confidentiality to Gleneagles and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information; 

d. Gleneagles’s dealers, agents, contractors, suppliers and other telecommunication, information service providers and content providers; 

e. Gleneagles’s professional advisers, including its accountants, auditors and lawyers; and 

f. Government and regulatory authorities and other organisations, as required or authorized by law or court order. Provided that where such provision requires cross border transfer of personal data, we will seek your consent in writing to the transfer and Gleneagles will take all reasonable precautions and exercise all due diligence to ensure that the data will not in that place where the personal data is to be transferred be collected, held, processed or used in any manner which, if that place were Hong Kong, would be a contravention of the requirement under the Personal Data (Privacy) Ordinance (Cap.486)(the Ordinance);

By providing personal information through the Mobile App, you are consenting to the disclosures described above.

9. Personal information may also be disclosed under Part 8 of the Ordinance as exemption from the provisions of the Ordinance.

10. Subject to your consent, we may also use your personal information for direct marketing purpose, or to send you materials and information on medical and health issues, or communications and notifications regarding services provided by Gleneagles and/or the Related Companies. Gleneagles and/or the Related Companies may contact you by telephone, SMS, mail, text messages and/or email.  You may withdraw your consent any time by sending a written request to Gleneagles: Health Information & Records Department, Gleneagles Hospital Hong Kong, 1 Nam Fung Path, Wong Chuk Hang, Hong Kong.  Upon receipt of your request, we will cease to use your personal information for direct marketing purpose.

11. Gleneagles will retain your personal information for a reasonable period of time that is necessary for the fulfillment of the purposes for which the personal information is collected or to comply with the legal, statutory, regulatory or accounting requirements.

12. Personal Data may also be collected, used, transferred or otherwise processed for one or more of the purposes set out in the Personal Data Protection Notice of our parent company IHH Healthcare Berhad.

13.  If you wish to require access to, correction or deletion of your personal information, you may do so under the Ordinance by sending a written request to Health Information & Records Department, B/F, Tower B, Gleneagles Hospital Hong Kong, 1 Nam Fung Path, Wong Chuk Hang, Hong Kong (Email: record@gleneagles.hk | Phone: +852 3153 9830).

14. Gleneagles reserves the right to amend or modify this Privacy Policy Statement from time to time without prior notification.  Any change to this Privacy Policy Statement shall be effective immediately upon posting.

15. This Privacy Policy Statement has been translated into Chinese. If there is any inconsistency or ambiguity between the English version and the Chinese version, the English version shall prevail.

16. If you have any enquiry, please email to enquiry@gleneagles.hk. 

January 2023