Privacy Policy

PLEASE READ THIS PRIVACY POLICY STATEMENT (“THE STATEMENT”) CAREFULLY AND EVERY TIME WHEN YOU ACCESS OUR WEBSITE AS THE STATEMENT MAY BE REVISED OR OTHERWISE CHANGED FROM TIME TO TIME WHERE WE DEEM NECESSARY.

Introduction

Zanolife Limited is committed to protecting the privacy and data security of the users of our website (“Website”). We are committed to protecting the privacy, confidentiality and security of the personal information we hold and we endeavour to ensure that all our collection, transmission, storage and usage of information provided to us (“Personal Data”) shall be carried out in compliance with, as amended, modified and supplemented from time to time, the Personal Data(Privacy) Ordinance(Chapter 486 of the Law of Hong Kong).We are equally committed to ensuring that all our officers, employees and agents uphold these obligations.

Where Zanolife collect any Personal Data from individuals in the European Union (“EU”) and the European Economic Area (“EEA”) for the purpose of providing services to that individual, under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the related and applicable legislation, Zanolife is the data controller for such Personal Data collected, and Zanolife is the representative in the EU.Zanolife is not required under the GDPR to appoint a Data Protection Officer and does not consider it appropriate to do so on a voluntary basis.

When this policy mentions “Zanolife”, “we”, “us” or “our”, it refers to Zanolife Limited which is responsible for your information under this Statement.

Scope

This Statement describes how Zanolife collects and uses your Personal Data in accordance with the Personal Data (Privacy) Ordinance (Chapter 486 of the Law of Hong Kong) and the GDPR.

Aims

This Statement tells you what Personal Data Zanolife collects, why we need it, how we use it and what protections are in place to keep it secure.

1. Information Collection & Use

1.1 Information You Provide to Us

During the use of our Website or in the course of Zanolife’s normal business activities, we may collect certain Personal Data about you including your first name, last name, contact details, date of birth and gender voluntarily provided by you to us. This information is necessary for conducting our normal business activities including sourcing and comparing health and wellness-related services offers for you or the organisation you represent (“Services”). Without it, we may not be able to provide you with all the requested Services.

Some Personal Data is collected automatically when you visit our Website. When any visitor links or connects to our Website, our web server automatically recognizes the visitor’s domain name and e-mail address where possible. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers.

1.2 Information You Choose to Give Us

We may further require certain sensitive information about you, including but not limited to your family medical history, your general lifestyle and your alcohol intake levels. You may choose to provide us with these additional personal information in order for us to provide you with all the requested Services. These additional Personal Data will be processed based on your consent.

1.3 Information We Receive from Third Parties

Zanolife may receive information, including personal information, from partners or individuals affiliated with Zanolife about you when they use our Website, or obtain information from other sources and combine that with information we collect through our Website. We do not control, supervise or respond for how the third parties providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

1.4 Disclosing of Information to Us

If you provide information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without our taking any further steps, we may process that information in accordance with this Statement.

When you provide information that enables us to respond to your request for the Services, you consent to our collection, use and disclosure of this information in association with our third-party partners (outside of Zanolife) for the purposes of effectively offering those Services and / or quotations for those Services. You also represent that any information you submit to us is accurate.

2 Why We Collect Your Personal Data

We collect and process the Personal Data provided by the users of the Website for our legitimate business interests in providing our users with the Services, including but not limited to internal marketing purposes, to improve the content of our Website, and for generally accepted business purposes such as data analysis. Our processing of the Personal Data provided by the users of our Website is based primarily on this justification. However, some uses of Personal Data is necessary to comply with applicable legal or regulatory requirements.

Specifically, we regularly use your Personal Data in the following ways:

  • to contact you regarding your enquiry;
  • to process your request for a health screening assessment via our platform;
  • for marketing, promotional and customer relationship management purposes, including sending you updates, news or offers;
  • to provide you with the information, products, and services that you request from us or which we feel may interest you;
  • for identification or verification purposes in connection with any product or service that may be supplied to you;
  • to facilitate the payment for products and services provided by us or our subsidiaries including verification of credit card details with ours and the relevant banks’ database
  • to ensure that content from our Website is presented in the most effective manner for you and your computer;
  • to notify you about changes to our Services;
  • to protect the integrity of our Website, our Services, and our reputation;
  • to prosecute or defend legal claims;
  • to protect other users of our Website;
  • prevention or detection of crime; and
  • disclosure as required by any law applicable in or outside of Hong Kong but only when we have a legal basis to do so.

You may decline to provide us with the requested Personal Data, but in such case we may not be able to process your request or provide full, accurate and comprehensive services to you.

3. Protection of Personal Data

We will protect your Personal Data by reasonable security safeguards against loss or theft, as well as unauthorised access, disclosure, copying, use or modification. While we have implemented safeguards, you should be aware that Internet security technology rapidly changes. We cannot guarantee that the safeguards we employ today can protect your Personal Data from the threats of tomorrow. You should also be aware that despite our efforts, factors beyond our control may result in disclosure of your Personal Data. Accordingly, we are not in a position to guarantee that your information will be secure under all circumstances.

4. Retention

Zanolife maintains and executes retention policies of records containing the Personal Data to ensure that the Personal Data is not kept longer than is necessary for the fulfilment of the purpose for which the Personal Data is or is to be used. Different retention periods apply to the various kinds of Personal Data collected and held by us.

5. Disclosure and Sharing of Personal Data

When you have provided consent, we may share your Personal Data as described at the time of consent to our partners, including but not limited to laboratories, clinics, hospitals and health screening centres located in Hong Kong, when you request us to provide you with the Services. This is in our mutual interest in ensuring we effectively provide you with the Services. We may disclose the Personal Data in the good faith belief that we are required to do so by law, or that doing so is reasonably necessary to comply with legal process, respond to any claims, or to protect the rights, property, or personal safety of Zanolife, our partners, or the public. Information, including the Personal Data, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition.

You should note that as Zanolife has no control over the acts of any third party, the Statement ceases to apply to any information that has been disclosed to a third party in accordance with this Statement. We endeavour to deal only with responsible third parties but assume no responsibility for the privacy protection provided by such third parties.

Zanolife does not sell, loan, trade or lease any Personal Data ascertained from our Website or by other means. We will not provide your Personal Data to third parties for other unrelated purposes without your consent.

6. Links

This Statement only applies to our Website but not other websites. Our Website may contain links to other websites and pages of third parties. By activating a link, such as for example by clicking on a hyperlink linking to another website or websites, you leave our Website and the Company does not exercise control over any Personal Data or any other information you give to any other entity after you have left our Website. Access to and use of such other websites is at your own risk and you are advised to refer to the privacy policies of those other locations (if any). We recommend that you review the privacy policies of third party websites.

7. Data Access, Correction & Removal

You have the right to request access to and correction of information held by us about you, as well as opt out of receiving any health check reminders and marketing promotions from us. The GDPR generally affords individuals a right to access their Personal Data, to object to the processing of their Personal Data, to rectify, to remove, to erase, to restrict and to port their Personal Data.

If you wish to opt out from receiving any future communication from Zanolife, to request for the rectification or deletion of your Personal Data that we collect, store or process, or have any questions with regards to our procedures for securely handling your data, please contact us at [email protected].

Zanolife is committed to providing you complete and current information about our Website, so that you are aware of the information Zanolife collects, how it is used and under what circumstances it may be disclosed. If you do not consent to the terms of this Statement, you should exit our Website now.

8. Amendment of Policy

We reserve the right to modify this Statement at any time. We will post the latest version of this Statement on our website. Please visit our website periodically. For material change of the policy, we will email customers or inform our users by posting a note on our Website for notification.

We keep our privacy policy statement under regular review. This statement was last updated on the date hereunder.

October 2018