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Privacy Policy - Pine Care Group

Privacy Policy

1. Commitment to Personal Data Protection

  1. Pine Care Group Limited ("Pine Care"), a part of Chinachem Group (“Chinachem Group”, “CCG”, “we”, “us”, or “our”), mean each of and collectively, Chinachem Group Holdings Limited and its holding companies, subsidiaries, affiliates and associated companies whose businesses and activities include property development, property sales and mortgage, property services, property leasing, operation of shopping malls and loyalty programme, hospitality, entertainment, healthcare, social services and charitable works.
  2. In handling personal data, Pine Care is committed to protecting your personal data privacy in accordance with the Personal Data (Privacy) Ordinance, Cap. 486 of the laws of Hong Kong (the "Ordinance").
  3. To enable you to make informed decisions about providing us with your personal data ("Data") when using our services, products, facilities or privileges, we outline in this Policy our policies and practices and the choices you have concerning the collection and use of your Data. This Policy sets out the kinds of Data which may be collected, the main purposes for which your Data may be used, and who you may contact for making data access requests and data correction requests.
  4. We may update this Policy from time to time. You are advised to review this Policy from time to time.

2. Types of Data We Collect

  1. The types of Data we collect from you will depend on (i) the nature of your relationship with Pine Care and (ii) the specific types of services, products, facilities or privileges as requested by or provided to you. The types of Data we collect may include:
    1. your personal information (e.g. your name, gender, date of birth, nationality, family status, passport or other identification number, address, religious beliefs and financial assistance information);
    2. your contact information (e.g. telephone number, mailing address and email address; emergency contact details, correspondence address);
    3. your credit card or other charge card information (e.g. name of cardholder, card number, billing address and expiry date);
    4. your insurance information;
    5. your medical and related information (e.g. medical records, health records, hospital discharge summaries, follow-up consultation records, referral letters, vaccination records and information relating to welfare benefits or government subsidies);
    6. biometric information (e.g. facial images and fingerprints); and
    7. photographs and video recordings; CCTV and security-related information.
  2. We stress that it is not obligatory for you to provide the Data to us. However, where the provision of certain Data is obligatory, we will inform you at the time of collection and explain the consequences of not providing it. If you elect not to provide such Data, we may not be able to supply or continue to supply you with the relevant information, services or products.

3. Purposes for which the Data are Collected and Used

  1. Depending on (i) the nature of your relationship with Pine Care and (ii) the specific types of services, products, facilities or privileges as requested by or provided to you, Pine Care and Chinachem Group may use the Data for one or more of the following purposes from time to time:
    1. to process your application or request for services, products, facilities or privileges;
    2. to provide services, products, facilities or privileges to you, and handle the necessary arrangements and matters (including legal, administrative and other matters) for maintaining and managing such services, products, facilities or privileges. These services, products, facilities or privileges may relate to the healthcare and wellness services, including residential care, nursing care, medical services, rehabilitation services, Chinese medicine services, health management, nutritional support, community care, caregiver support services and other services relating to the well-being of elderlies;
    3. to assess, plan, arrange, provide, coordinate, refer or follow up on the care, medical, rehabilitation, Chinese medicine, health management, community support, caregiver support and other related services required by you;
    4. to safeguard the health, safety and well-being of residents and to provide appropriate care services;
    5. to process, apply for, administer or verify matters relating to healthcare vouchers, government subsidy schemes, publicly funded service programmes, welfare schemes or other support programmes relevant to you;
    6. to facilitate the use of electronic health records, telehealth services, information technology platforms, health monitoring systems or other digital health services in support of the provision, administration and continuous improvement of care services;
    7. to verify your identity and accuracy of the Data;
    8. to maintain security of Pine Care residence and safety of the residents therein;
    9. to calculate any amount payable by you or to you in connection with the relevant services, products, facilities or privileges;
    10. to collect or recover any amount or indebtedness owing by you in any capacity;
    11. to enforce the terms of any contract or arrangement between you and/or Pine Care or any Chinachem Group member and to take suitable action to protect or preserve the rights or benefits of Pine Care and any Chinachem Group member;
    12. to communicate with you and for overall relationship management and maintenance;
    13. to investigate, handle and respond to any comments, messages, requests, enquiries, complaints or incidents made by you, made against you or involving you in any manner;
    14. to conduct survey, research and analysis to facilitate the provision of services, products, facilities, privileges, activities or events to you or to customers generally;
    15. to comply with any obligations or requirements for using or disclosing personal data that are imposed on any Chinachem Group member by any law or regulations, or by any governmental agency, regulatory authority, law enforcement agency, court or judicial body, whether in or outside of Hong Kong existing currently or in the future;
    16. (where Pine Care or any Chinachem Group member believes in good faith that use or disclosure of personal data is necessary) to protect the rights or properties of Pine Care or any Chinachem Group member, or to identify, contact or bring legal action against any person who may be causing damage to or interference with the rights or properties of any Chinachem Group member (whether intentionally or otherwise), or when any other person could be harmed by such activities;
    17. to enable actual or potential purchasers or assignees of Pine Care or any Chinachem Group member or its business and assets (or any part of them), in each case to evaluate the purchase or assignment in question; and
    18. to fulfill other purposes directly related to any of the foregoing purposes, or other purposes as you may agree from time to time.
  2. We will not knowingly or intentionally use, disclose, sell or rent the Data provided to us for purposes other than or that are unrelated to those set out above without your consent.

4. Disclosure and Transfer of Data

  1. Pine Care and Chinachem Group will keep the Data confidential but may disclose or transfer the Data to one or more of the following classes of persons from time to time for the purposes set out in paragraph 3 above:
    1. any Chinachem Group members in connection with the provision of their services, products, facilities or privileges;
    2. any agents, sub-agents, suppliers, contractors, sub-contractors or service providers (including their employees, directors, officers, agents and service providers) who provide services or support to any Chinachem Group member in connection with its business or operations in general. These services or support may include marketing, data storage, data processing, administrative, telecommunications, or computer services. These agents, sub-agents, suppliers, contractors, sub-contractors or service providers may or may not be Chinachem Group members;
    3. Hospital Authority and hospitals, clinics or the like offering diagnosis, medical treatment, consultation, counselling or rehabilitation etc.;
    4. medical practitioners, registered Chinese medicine practitioners, laboratories, pharmacies, rehabilitation service providers, healthcare service providers or other relevant service partners involved in the care, nursing, medical, rehabilitation or health management services received by you, for the purpose of providing, coordinating, arranging or following up on such services;
    5. government departments, public bodies, charitable organisations, social service agencies, community service providers or other collaborative partners (including but not limited to organisations providing elderly services, caregiver support services, community care services, health promotion services and welfare support services) for the purpose of arranging, referring, providing or coordinating relevant services. Such organisations may include, without limitation, the Social Welfare Department, Hospital Authority, Department of Health, relevant agencies under the Health Bureau, organisations participating in the Elderly Health Care Voucher Scheme, and providers of electronic health record systems, telehealth services, health monitoring platforms, information technology systems or related technical support services to facilitate the provision, administration and enhancement of care service quality and operational efficiency;
    6. any person to whom any Chinachem Group member is under any obligation or requirement to disclose personal data in compliance with law, regulation or court order, or in response to lawful request by any governmental agency, regulatory authority, law enforcement agency, court or judicial body, or in case any Chinachem Group member believes in good faith that disclosure is necessary for (including but not limited to) protection of its rights or properties, or to identify, contact or bring legal action against any person who may be causing damage to or interference with its rights or properties (whether intentionally or otherwise), or when any other person could be harmed by such activities;
    7. any person to whom any Chinachem Group member is required to disclose personal data by any policies and measures implemented by the Chinachem Group for prevention or detection of money laundering, terrorist financing or other unlawful activities;
    8. any person who owes a duty of confidentiality to any Chinachem Group member, including accountants, auditors, legal advisers and other professional advisers;
    9. any independent contractor or agent appointed by Pine Care or any Chinachem Group member to conduct assessment and investigation of your ability to perform your obligations and, where appropriate, your credit worthiness, financial status and repayment ability;
    10. any debt collection agency, where you default in paying any amount or indebtedness; and
    11. any actual or potential purchaser or assignee of any Chinachem Group member or its business and assets.
  2. The Data may be transferred in or out of Hong Kong to any of the persons set out above. By providing the Data to any Chinachem Group member, you agree that Chinachem Group may transfer the Data outside Hong Kong.
  3. Where the Data is transferred outside Hong Kong, we will take reasonably practicable steps to ensure that the Data transferred outside Hong Kong is protected by standards in line with the requirements of the Ordinance, subject to any other requirements and limitations applicable in the relevant overseas jurisdiction.

5. Data Retention

The Data you provide to us will be kept by us only for as long as it is necessary to fulfill the purposes set out in paragraph 3 above. The Data after which it will be destroyed in accordance with the Ordinance after the purposes have been fulfilled.

6. Use of Cookies

In order to provide you with better user experience and customizable and personalized services on our websites, “cookies” may be created and saved on your computer. Cookies are small text files that are automatically created and stored on your web browser in your computer or other access device (e.g. a smart phone or tablet) which can be retrieved by our websites. Cookies will store information about your site preferences (e.g. if you inquire about rates and availability, the site might create a cookie that contains the details you entered), navigation pattern, your login name, etc and be used to track visits to our websites but will not collect or store any information by accessing the rest of your computer. For example, our websites cannot determine your name, address, telephone number or any similar information unless you choose to type it on any of our websites. Most web browsers automatically accept cookies, but if you prefer, you can at any time disable the cookies in your web browser. However, by disabling the cookies, you will be unable to use some of the features of our websites.

7. Log Files

We may also collect information regarding your IP address, browser type, domain name and access time ("Log Files"). Log Files are primarily used for our own research purposes and are kept separately from the Data. In certain circumstances permitted by the Ordinance, IP addresses may be used to assist in investigating, deterring and/or preventing abusive or criminal activity on our websites.

8. Our Commitment to Data Security

  1. To maintain the accuracy of the Data, as well as preventing unauthorised access and ensuring the correct use of the Data, we have carried out appropriate measures to safeguard and secure the Data we collect. We use an industry standard for encryption over the Internet known as Secure Socket Layer (SSL) protocol, to protect the Data.
  2. We install a firewall on our websites to protect the Data against unauthorised or accidental access. However, complete confidentiality and security is not possible over the Internet, and data privacy cannot be absolutely assured in your communications with us. You acknowledge and accept the risk of unauthorised or accidental access of the Data. This may result in, among others, you receiving unsolicited messages from other parties. We are not responsible in any manner for direct, indirect, special or consequential damages that you may incur or suffer caused by or arising from your communications with us. You are advised to take precautionary measures against unauthorised access to any passwords and financial information such as credit card details. You should make sure you sign out or log out from your account after use particularly when using a shared computer.

9. Other Websites

  1. Our websites may contain links to external third party websites ("external website(s)"). Your access to and use of an external website is at your own risk and subject to the terms and conditions, and privacy policies and practices applicable to the external website.
  2. All external websites are independent from our websites. Chinachem Group has no control over the external websites, their contents or the terms and conditions governing their use, or their privacy policies and practices. We do not give any warranty or representation for the quality or security of any external websites. You should therefore be fully aware that the provision of the link to an external website does not constitute an endorsement, approval, recommendation or any form of cooperation or association by or with any Chinachem Group member. You should therefore remain alert when you click on a link to leave any of our websites and enter an external website, and you should read the terms and conditions and privacy policies of that external website.

10. Use of the Data in Direct Marketing

  1. Each Chinachem Group member that collects the Data intends to use the Data in direct marketing and that member requires your consent for this purpose. Please note the following:
    1. Types of Data to be used

      That Chinachem Group member may use the following types of Data that is held by it from time to time in direct marketing:

      1. your name, address, telephone number, email address and other contact information;
      2. pattern and behaviour relating to your use, purchase or consumption of services, products and facilities (including services and products portfolio information and spending habits); and
      3. your demographic data.
    2. Classes of services, products and subjects to be marketed

      That Chinachem Group member may market one or more of the following classes of services, products and subjects:

      1. real estate properties or property developments offered for sale and/or leasing by that member or any other Chinachem Group member singly or jointly with any other developer or person from time to time;
      2. mortgage loan and other credit facilities;
      3. hotel, conferencing facilities and services, restaurants, food and beverages, amenities and entertainment;
      4. healthcare and related products or services; and
      5. donations or contributions for charitable or non-profit making purposes and related activities or events.
    3. Providers of services, products and subjects to be marketed

      The above services, products and subjects may be provided by one or more of the following classes of persons:

      1. that Chinachem Group member;
      2. other Chinachem Group members; and
      3. Group Partners (and the names of these Group Partners can be found in the application form or information leaflet relating to the relevant services, products and subjects). Group Partners may include real estate developers, financial institutions, retail merchants, service providers, charitable bodies and non-profit making organisations, providers of healthcare and related products or services.

    Unless we receive your consent, Chinachem Group may not provide your Data to the Chinachem Group members and/ or Group Partners for direct marketing use.

    You always have ultimate choice and control over the type of information you would like to receive from us. When you use our online services or receive our promotional materials, you will have the chance to indicate your choice to receive, or not to receive in future, promotional materials from us. Should you decide not to receive any updates from us, feel free to cancel your subscription to these services by contacting us via the contact information provided on the websites or as indicated in the relevant materials. Please allow reasonable time for us to cancel your subscription to these services.

11. How to Access or Correct Your Data or Contact Us

  1. You are entitled to ascertain whether we hold your Data, request access to your Data and correction of any of your Data which is inaccurate. If you wish to obtain a copy of any of your Data or to correct your Data, please issue a request in writing to our Data Protection Officer at office@pinecaregroup.com or at the following address:

    Chinachem Group (Attention to Pine Care Group)
    37th Floor, Nina Tower,
    8 Yeung Uk Road
    Hong Kong

  2. In accordance with the provisions of the Ordinance, we have the right to charge a reasonable fee for the processing of any data access request.

12. Access to Data Privacy Policy Statement

  1. You may access and obtain a copy of this notice, as amended from time to time from our websites, or from the address set out in paragraph 11 above.
  2. Nothing in this notice shall limit your rights as a data subject under the Ordinance.

This Policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Policy, the English version shall prevail.

Privacy Policy - Addendum

This Addendum (“Addendum”) is made for compliance with the Personal Information Protection Law of the People’s Republic of China, and shall form an integrate part of the Privacy Policy (“Privacy Policy”). However, it shall apply only to people who resided in or who are in Mainland China using our website, service or product ("we", "us" or "our"). In case of any discrepancy between any provision herein and any other provision in the Privacy Policy, the provision herein shall prevail.

Before providing your personal data to us, please ensure that you have carefully read this Addendum.

1. Collection, Disclosure, Sharing, Transfer and Publication of Personal Data

1.1 Collection of Sensitive Personal Information

The personal data that we may collect in order to provide the service or product you have purchased may contain your sensitive personal information, which means any personal information that once disclosed, provided illegally or misused, may endanger your personal or property safety and may extremely easily lead to any harm to your reputation or health in body and mind or any other discriminatory treatment. When it becomes necessary to collect any sensitive personal information from you, we will solicit your consent in advance.

1.2 Disclosure and Sharing of Personal Data

Except otherwise provided for in any applicable law or regulation or required by any competent regulatory authority, we will only disclose to or share with any third party your personal data, as necessary for the related service, in the circumstances set forth in Article 4 of the Privacy Policy. We will enter into a non-disclosure agreement with such third party, under which the third party should be required to process your personal data pursuant to the Privacy Policy and its Addendum and other related confidentiality and security measures. Such third party shall not be entitled to subject the personal data to any other purpose than specified in the Privacy Policy and its Addendum. We will solicit your consent by means of a written agreement or a pop-up window, pursuant to any applicable law or regulation or standard and with your explicit consent, will provide to or share with the third party your personal data.

If you need to know any company, organization or individual who is involved in the circumstances under the Privacy Policy, please send an email to office@pinecaregroup.com, noting “Third-Party Data Inquiry” in the subject line, to which we will respond within 15 working days of receiving the email.

1.3 Transfer of Personal Data

We will not transfer your personal data to any third party, unless:

  1. Your prior explicit consent or authorization has been obtained.
  2. It involves any merger, acquisition, or insolvency and liquidation proceedings, where, if the transfer of your personal information is involved, We will require that any succeeding third party that comes to hold your personal data continue to be bound by this Privacy Policy and its Addendum; otherwise, we will require that such third party resolicit your authorization or consent.

1.4 Public Disclosure

We will not disclose your personal data to the public, unless:

  1. Your prior explicit consent has been obtained (for example, in any public event organized by us, we will not disclose to the public the personal data of the winner unless and until the explicit authorization and consent from the winner is obtained).
  2. We do so pursuant to any mandatory requirement of any applicable law or regulation, legal proceeding or competent government authority.

2. Protection and Storage of Personal Data

2.1 Protection of Personal Data

We will protect your personal data in strict compliance with Article 8 of the Privacy Policy, and ensure that no personal data unrelated to the use of our service or product shall be collected. In the event of any personal data breach, We will promptly inform you of the breach and its possible consequence, the action we have taken or will take, and any action you may take, pursuant to the applicable law or regulation. We will promptly notify you by email, regular mail, telephone or push notification and if it is too difficult to reach all the owners of the personal data, we will make a public announcement in a reasonable and effective manner.

3. Your Rights

Pursuant to applicable laws, regulations and standards of the People’s Republic of China and any other national or regional practice, you may exercise the following rights to your personal data:

3.1 To access your personal data

You may do this by sending an email to office@pinecaregroup.com, noting “Personal Information Inquiry” in the subject line. We will respond to your inquiry within 15 working days.

3.2 To correct your personal data

You may do this by sending an email to office@pinecaregroup.com, noting “Personal Information Correction Request” in the subject line. We will respond to your correction request within 15 working days.

3.3 To delete your personal data

You may require that your personal data be deleted by contacting us in the way specified in Article 11 of the Privacy Policy, to which we will respond within 15 working days to confirm your deletion request, if:

  1. Our processing of your personal data violates any applicable law or regulation;
  2. We have collected and used your personal data without first obtaining your consent;
  3. Our processing of your personal data breaches any agreement with you;
  4. You cease using our product or service, or cancel your member account with us (if applicable); or
  5. We cease providing you with product or service.

If we decide to respond to your deletion request, we will also inform any entity who receives your personal data from us to delete your personal data in timely manner, unless otherwise provided for in any applicable law or regulation or if such entity has independent authorization from you.

When your personal data is removed from our service system, we may not immediately delete the same from our backup system until the related backup is updated.

3.4 To change or withdraw the scope of your authorization

Different personal data may be required in order for us to provide certain service or product. You may change the scope of personal data you have agreed for us to use or process, or withdraw your authorization or consent, with respect to any service or product, by sending an email to office@pinecaregroup.com. We will respond within 15 working days to confirm your request. When you withdraw your consent, we will cease processing your personal data concerned and may be unable to continue to provide relevant service or product for you, which, however, will not affect any previous processing of your personal data on the basis of your consent.

3.5 To cancel your member account (if applicable)

You may require that your member account be canceled with our website, by contacting us in the way specified in Article 11 of the Privacy Policy, to which we will respond within 15 working days to confirm your cancellation request. After your member account is canceled, we will cease providing the related service or product for you, stop collecting your personal data, and if you so request, delete your personal data under the member account, unless:

  1. It is otherwise provided for in any applicable law or regulation;
  2. Your member account cannot be canceled under the relevant requirements of the competent administrative, judicial or other authority; or
  3. While using any of our service or product, you have seriously violated any law, regulation or contract and/or any policy or terms and conditions that we formulate for the service or product.

3.6 To obtain a copy of your personal data

You may request a copy of your personal data by contacting us in the way specified in Article 11 of the Privacy Policy, to which we will respond within 15 working days.

3.7 To restrict the Information System in automated decision-making

For certain services, we may make decisions solely on the basis of nonhuman automatic decision-making mechanisms, including the Information System or algorithms. If any of your legal rights or interests is significantly affected, you may require an explanation or refuse to accept our decisions made by the automated decision-making system, by contacting us in the way specified in Article 11 of the Privacy Policy, to which we will respond within 15 working days.

3.8 To respond to your requests hereinabove

  1. For security reasons, we may require that you should provide a written request or identify yourself in any other way. We may also require that your identification be verified before your request may be processed. We will respond to you within 15 working days of receiving your request.
  2. We will not charge you, in principle, if you have raised a reasonable request, but may ask you to pay for the cost, depending on the situation, if the same request has been raised for multiple times or the reasonable extent is exceeded. We may reject any request that is unreasonable and filed repeatedly, that require us to offer any technical means that we cannot reasonably offer (for example, to develop a new system or fundamentally change the existing practice), or that brings any risk to any legal right or interest of any other person, or that is too hard to be feasible (for example, to create a backup copy for the information stored on the magnetic tape).
  3. Also, if it is so required under any special provision of any applicable law or regulation, or pursuant to any legitimate requirement of any administrative, judicial or other competent authority, we may not be able to respond to your request.

4. Language

In case of any discrepancy between the English and Chinese version contained herein, the Chinese version shall prevail.