MALAYSIA 
SINGAPORE Privacy Policy
EYS MS Clinic Policy (the “Policy“)
This Policy is governed by the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Privacy Ordinance”) and all customers of Eu Yan Sang Medical Services Ltd. (“EYS MS”) and users of https://hk.euyansangclinic.com (the “website”) (“you”, “your”, and collectively, the “Users”) shall abide by its relevant provisions. EYS MS collects, uses, processes and discloses Users' Personal Data (as defined below) to create a safe, smooth, efficient and personalized experience for you. This Policy outlines EYS MS's policies and responsibilities regarding the collection, use, process and disclosure of Personal Data.
For the purposes of this Policy, Personal Data means data, relating directly or indirectly to a living individual, from which it is practicable for the identity of the individual to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable. This includes data and other information which EYS MS has or is likely to have access to, including (but is not limited to) the User’s name, date of birth, gender, phone number, email address, residential or other address, and payment account information.
By continuing to use EYS MS's services, you represent that you have read, understood and agreed to be bound by this Policy, as may be amended by EYS MS from time to time.
1. Personal Data collection statement
1.1 EYS MS will collect your Personal Data in accordance with the Privacy Ordinance.
1.2 Please note that Users of our website may be required to provide certain Personal Data in order to access the website and the services provided by EYS MS.
1.3 EYS MS will notify you of the purposes for which your Personal Data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your Personal Data for the intended purposes, unless exceptions under applicable laws permit EYS MS to collect and process your Personal Data without notification to or consent from you.
2. Consent
2.1 Before EYS MS collects, uses or discloses your Personal Data, EYS MS will notify you of the purposes for which EYS MS is doing so. EYS MS will obtain written confirmation from you on your expressed consent.
2.2 Under certain circumstances and to the extent permitted under the Privacy Ordinance, EYS MS may assume deemed consent from you when you voluntarily provide your Personal Data for the stated purpose. This includes browsing and using this website or registering for or using services on the website.
3. Use and disclosure of Personal Data
Uses of Personal Data
3.1 EYS MS will collect, retain and use the User’s Personal Data collected by EYS MS for the following purposes:
(a) rendering medical and consultancy services to you;
(b) considering and/or processing your transaction with EYS MS, as the case may be;
(c) facilitating, processing, dealing with, administering, managing and/or maintaining your transaction, as the case may be;
(d) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
(e) managing and/or administering your use and/or access of the website;
(f) managing, operating, administering and providing you the services offered on the website;
(g) for identification and/or verification;
(h) for contacting you on matters relating to your transactions on the website and your requested services on the website, and any enquiries and/or requests submitted by you through the website or otherwise;
(i) social media marketing using direct and open graph techniques (if you have consented to the same);
(j) for digital and conventional marketing purposes such as sending you direct mailers and post about new products, special offers or other information which EYS MS think you may find interesting (if you have consented to the same);
(k) publishing Users review in digital and print format to open public (if you have consented to the same);
(l) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your transaction with us. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of any medicine or medical supplies as well as on the external cover of envelopes/mail packages;
(m) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether relating to your transaction with us or any other matter arising from your transaction with us, and whether or not there is any suspicion of the aforementioned;
(n) complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding or non-binding on EYS MS and/or for the purposes of any guidelines issued by regulatory or other authorities, whether in Hong Kong or elsewhere;
(o) complying with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities, whether in Hong Kong or elsewhere. For the avoidance of doubt, this means that EYS MS may/will disclosure your personal data to the aforementioned parties upon their request or direction;
(p) conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve EYS MS services and facilities in order to enhance your relationship with EYS MS or for your benefit, or to improve any of EYS MS products or services for your benefit;
(q) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Hong Kong;
(r) any other purposes which EYS MS may notify you of at the time of obtaining your consent; and
(s) to fulfill any other purposes directly related to (a) to (r) above
Disclosure of Personal Data
3.2 The user further agrees that EYS MS may disclose and transfer the User's Personal Data to third-party service providers engaged by EYS MS to assist EYS MS in providing services to the User (including data input, management of customer database, and any inquiries in our stores or Products provided by the website to process, carry out and verify related sales, ordering, refund service and/or replacement service, contact users about promotions, delivery services and other customer services, and process Users' Personal Data in a safe situation (“Third Party Service Providers“). All Third Party Service Providers are obliged to maintain confidentiality with EYS MS and are only permitted to use the User's Personal Data for the purposes set out in paragraph 3.1 above, and shall not use the User's Personal Data for its own purposes (including direct marketing purposes).
3.3 EYS MS may further disclose and transfer (whether in Hong Kong or overseas) Users’ Personal Data to EYS MS’s affiliates, professional consultants, persons or companies acting for or on EYS MS’s behalf, partners, clients, promoters, agents, contractors, suppliers, other service providers, law enforcement agencies, insurance companies, government and regulatory agencies and other organizations when necessary for the purposes set out in paragraph 3.1 above.
3.4 In addition, please note that EYS MS may disclose your Personal Data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) cases in which the disclosure is required or authorized based on the applicable laws and/or regulations (whether in Hong Kong or elsewhere), whether binding or non-binding on EYS MS;
(b) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(c) cases in which the disclosure is necessary for any investigation or proceedings (whether in Hong Kong or elsewhere), whether binding or non-binding on EYS MS;
(d) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(e) where such disclosure without your consent is permitted by law.
3.5 Please note that the above list of exceptions is not meant to be exhaustive. For more information on the applicable exceptions, please refer to the Privacy Ordinance.
3.6 EYS MS may share the general data of Users whose identity cannot be identified with third parties for any purpose (including marketing and publicity), and may use such data to better understand Users' needs and improve EYS MS's products and services.
3.7 Any Personal Data collected by EYS MS will be retained by EYS MS and may be transferred to or inspected by EYS MS's employees, third-party service providers and third-party organizations engaged by them for the purposes set out in paragraph 3.1 above.
4. Security of Personal Data
4.1 EYS MS makes every reasonable effort to ensure that all Personal Data held by EYS MS is stored in a safe and secure place and can only be accessed by authorized personnel or third-party service providers.
4.2 EYS MS takes Personal Data collected through EYS MS’s clinics and this website seriously. All Personal Data collected on the website will be protected by encrypted servers. In addition, SSL (Secure Sockets Layer) will protect the transmission of data from the internet to the system.
4.3 For example, when you send sensitive information through a website, this information will be encrypted before being sent to the internet.
4.4 To further enhance your online transactions, EYS MS also employs related software programs to monitor network traffic to identify unauthorized attempts to upload or change User’s Personal Data, perpetuation of fraudulent or illegal activities, or other conduct that may cause damage. If monitoring reveals evidence of possible abuse or criminal activity, such evidence will be provided to relevant law enforcement agencies or authorities without prior notice to the User.
4.5 Please note that it is possible for any system to be intruded, and it is impossible to guarantee that any information provided on the internet is completely safe. Accordingly, EYS MS cannot guarantee the security of information transmitted by Users to EYS MS or received by Users from EYS MS over the internet.
5. Direct Marketing
5.1 Subject to obtaining your consent and any subsequent withdrawal of consent, EYS MS may use your Personal Data for the purpose of sending direct marketing (whether by messaging within EYS MS’s services, by email or by other means) that offer or advertise EYS MS’s products and services and/or the products and services of selected third parties. Such products and services (of ours or third parties) include the following:
(a) EYS MS’s products and services and the products and services of EYS MS’s affiliate and subsidiary companies and business partners; and
(b) third party providers of the above services and products and services and other products and services that EYS MS thinks may be relevant to you.
5.2 EYS MS will honour your request to not use your Personal Data for the marketing purposes noted above. If you wish to make such a request, please submit the request to EYS MS. The relevant contact details may be found below at paragraph 15.
5.3 Please note that EYS MS will not share your Personal Data with any advertisers unless you have given your consent for EYS MS to do so.
5.4 For the avoidance of doubt, this consent is separate from and independent of the consent provided by you for the use of your Personal Data in accordance with this Policy (save for this Clause). Accordingly, it can be withdrawn at any time without reference to this Policy and/or the duration of the services.
6. Right to access, correct or delete Personal Data
6.1 In accordance with the Policy, Users have the right to review, request or correct their Personal Data held by EYS MS (if necessary).
6.2 Users may request deletion, cessation of processing or utilization of Personal Data. However, this does not apply to those necessary for EYS MS to perform its duties or business. If Users have any questions about this Policy, or if they want to view, correct or delete their Personal Data, they can send an email to EYS MS personal data protection officer. The relevant contact details may be found below at paragraph 17.
6.3 For any request to access Personal Data, once EYS MS has sufficient information from you to verify your identity and to deal with the request, EYS MS will seek to provide you with the relevant Personal Data within the time period prescribed under the Privacy Ordinance. Where EYS MS is unable to respond to you within a reasonable period, EYS MS will notify you of the reason and if applicable, of the soonest possible time within which EYS MS can provide you with the information requested.
6.4 For a request to correct Personal Data, once EYS MS has sufficient information from you to verify your identity and to deal with the request, EYS MS will:
(a) correct your Personal Data within the time period prescribed under the Privacy Ordinance. Where EYS MS is unable to do so within such time period, EYS MS will notify you of the reason and if applicable, of the soonest practicable time within which EYS MS can make the correction; and
(b) EYS MS will send the corrected Personal Data to every other organisation to which the Personal Data was disclosed by EYS MS within a year before the date the correction was made unless that other organisation does not need the corrected Personal Data for any legal or business purpose.
6.5 In accordance with the Policy and/or the Privacy Ordinance, EYS MS reserves the right to charge Users a reasonable fee for processing any request to access, correct or delete Personal Data.
7. Accuracy of Personal Data
EYS MS will take reasonable efforts to ensure that your Personal Data is accurate and complete if your Personal Data is likely to be: (i) used by EYS MS to make a decision that affects you or (ii) disclosed to another organisation. However, this means that you must also update EYS MS of any changes in your Personal Data that you had initially provided EYS MS with. EYS MS will not be responsible for relying on inaccurate or incomplete Personal Data arising from you not updating EYS MS of any changes in your Personal Data that you had initially provided EYS MS with.
8. Retention of Personal Data
EYS MS will also put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.
9. Transfer of Personal Data
Where your Personal Data is to be transferred out of Hong Kong, EYS MS will comply with the Privacy Ordinance in doing so. This may include EYS MS entering into an appropriate contract with the foreign recipient organisation dealing with the Personal Data transfer or permitting the Personal Data transfer without such a contract if the Privacy Ordinance requires EYS MS to do so.
10. Cookies
10.1 EYS MS may use cookies (“Cookies“) on this website to:
(a) make security measures more stringent;
(b) to enable online Users to continue browsing the website; and
(c) provide individual Users with personalized web pages according to their needs.
10.2 Cookies are stored in the User's hard drive, and contain information about the User's preferences when using EYS MS's website, so that EYS MS's website can be adjusted to suit the User when the User browses the next time.
10.3 If Users choose not to receive cookies, the Users can close the cookies. Users can also set the computer to send out reminders whenever cookies are used. Both options require the User to adjust browser settings (such as Internet Explorer). There are also software products that allow Users to manage these cookies. Please note that when the browser is set to reject cookies, it may also limit the functionality of the website the User is visiting, and the User may not be able to use certain functions.
11. Clickstream data
To improve your online experience, EYS MS may track online behavior or clickstream data to assist Users in using the website and track the processing of submissions from other sites. This data is not stored on User records and is collected for statistical analysis purposes only.
12. Minors
EYS MS is unable to differentiate the age of those who use our website. If minors (according to applicable laws) provide EYS MS with Personal Data without the consent of their parents or guardians, their parents or guardians should contact EYS MS to delete the minor's User information.
13. Web links
For the convenience and reference of Users, EYS MS also provides links to other websites. Users access these sites at their own risk and EYS MS is not responsible for the content contained on these sites. Although EYS MS protects Personal Data on the website, it has no control over the policies of other websites or the sharing of Personal Data by Users to other websites, and is not responsible for it. Please note that this Policy does not cover other websites, so EYS MS recommends that you also need to understand the specific policies of other websites.
14. Google analytics
Google Analytics is a web analytics service provided by Google. Google uses the data collected and tracks and studies the use of shop.euyansang.com.hk to prepare reports on its activities and to share this data with other Google services. Google may use the data collected to personalize advertisements and its advertising network. For more details, please refer to Google's Policy.
15. Contact Details
For any enquiries or further information on this Policy, please contact EYS MS at:
Contact: Data Protection Officer Address: EYS HK Centre, 10 Wang Lee Street, Yuen Long Industrial Estate, Yuen Long, New Territories, Hong Kong Email: pdpo.eyshkclinic@euyansang.com
16. Updates to the Policy
EYS MS will revise or update this Policy from time to time, and post it on this website with a date to let Users know when the Policy was last updated. The English version of this Policy supersedes any version thereof written in another language under applicable law. In the event of any discrepancy between the English version of the Policy and any translation, the English version of the Policy shall prevail.