Privacy Policy
Introduction
Welcome to Apricot Medical Technology Limited’s (“Apricot”, “We” or “Us” or “Our”) privacy policy (“Privacy Policy”).
Apricot respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how We look after your personal data when you visit Our website (regardless of where you visit it from) or use Our software applications and tell you about your privacy rights and how the law protects you.
How Our services work
Apricot operates the medical practice management software application VITA for healthcare providers (“VITA”) as well as the mobile application E+BOOK, which is an integral part of VITA (“E+BOOK”). VITA and E+BOOK are being used by healthcare providers in order to collect your personal data in relation to providing their healthcare services to you. In general, We process the personal data collected by doctors and clinics in order to facilitate their services to you. However, We may collect, use, store and transfer personal data if you are an individual doctor using VITA or if you use E+BOOK to make an appointment with a doctor or a clinic.
Apricot respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how We look after your personal data when you visit Our website (regardless of where you visit it from) or use Our software applications and tell you about your privacy rights and how the law protects you.
How Our services work
Apricot operates the medical practice management software application VITA for healthcare providers (“VITA”) as well as the mobile application E+BOOK, which is an integral part of VITA (“E+BOOK”). VITA and E+BOOK are being used by healthcare providers in order to collect your personal data in relation to providing their healthcare services to you. In general, We process the personal data collected by doctors and clinics in order to facilitate their services to you. However, We may collect, use, store and transfer personal data if you are an individual doctor using VITA or if you use E+BOOK to make an appointment with a doctor or a clinic.
Important Information and Who We Are
Purpose of this privacy policy
This Privacy Policy aims to give you information on how We collect, process, use and share personal data through the use of VITA and E+BOOK, including any data you may provide when you purchase a product, service or other features offered by Apricot (“Services”).
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy We may provide on specific occasions when We are collecting or processing personal data so that you are fully aware of how and why We are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
We are committed to keeping and safeguarding your personal information and data to its privacy and confidentiality. This Privacy Policy is prepared in accordance with the Personal Data (Privacy) Ordinance (Cap. 486).
By using or downloading Our Services, and providing your information thereto, you shall be deemed to consent to this Privacy Policy and you agree and understand each clause hereof. Please take a moment to familiarize yourself with Our privacy practices and contact Us if you have any questions.
Third party links
Our Services may, from time to time, contain links to and from the websites of Our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
This Privacy Policy aims to give you information on how We collect, process, use and share personal data through the use of VITA and E+BOOK, including any data you may provide when you purchase a product, service or other features offered by Apricot (“Services”).
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy We may provide on specific occasions when We are collecting or processing personal data so that you are fully aware of how and why We are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
We are committed to keeping and safeguarding your personal information and data to its privacy and confidentiality. This Privacy Policy is prepared in accordance with the Personal Data (Privacy) Ordinance (Cap. 486).
By using or downloading Our Services, and providing your information thereto, you shall be deemed to consent to this Privacy Policy and you agree and understand each clause hereof. Please take a moment to familiarize yourself with Our privacy practices and contact Us if you have any questions.
Third party links
Our Services may, from time to time, contain links to and from the websites of Our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Collection of Personal Data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
In general, We process personal data collected by doctors and clinics through VITA and E+BOOK. A typical scenario would be when a healthcare provider records information about a patient which may include: complaints /findings /diagnosis /actions during a consultation, drug prescriptions details, health data and medical laboratory data if applicable (e.g. BMI, Blood Pressure, Glucose Level, etc.), and any other health/medical related data that the doctors wish to upload to our systems (e.g. X-Ray /Radiology images, etc.)
However, in order to provide our Services, We may collect, use, store and transfer different kinds of personal data which We have grouped together as follows:
In general, We process personal data collected by doctors and clinics through VITA and E+BOOK. A typical scenario would be when a healthcare provider records information about a patient which may include: complaints /findings /diagnosis /actions during a consultation, drug prescriptions details, health data and medical laboratory data if applicable (e.g. BMI, Blood Pressure, Glucose Level, etc.), and any other health/medical related data that the doctors wish to upload to our systems (e.g. X-Ray /Radiology images, etc.)
However, in order to provide our Services, We may collect, use, store and transfer different kinds of personal data which We have grouped together as follows:
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Identity Data includes identity number (e.g. HKID), first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
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Contact Data includes billing address, delivery address, email address and telephone numbers.
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Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website or Our Services.
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Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
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Usage Data includes information about how you use Our website, products and Services.
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Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
If you use E+BOOK, We may also collect, use, store and transfer your Medical Data which includes information about your previous healthcare providers, your reason for visit and your date of visit, your payment method and other medical information you choose to share with Us.
Aggregated Data
We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, We may aggregate your Usage Data to calculate the percentage of users accessing a specific website or software application feature. However, if We combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). Nor do We collect any information about criminal convictions and offences.
If you fail to provide personal data
Where We need to collect personal data by law, or under the terms of a contract We have with you, and you fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with you (for example, to provide you with goods or services). In this case, We may have to cancel a product or service you have with Us but We will notify you if this is the case at the time.
If you use E+BOOK, We may also collect, use, store and transfer your Medical Data which includes information about your previous healthcare providers, your reason for visit and your date of visit, your payment method and other medical information you choose to share with Us.
Aggregated Data
We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, We may aggregate your Usage Data to calculate the percentage of users accessing a specific website or software application feature. However, if We combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). Nor do We collect any information about criminal convictions and offences.
If you fail to provide personal data
Where We need to collect personal data by law, or under the terms of a contract We have with you, and you fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with you (for example, to provide you with goods or services). In this case, We may have to cancel a product or service you have with Us but We will notify you if this is the case at the time.
How is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
Direct interactions
You may give Us your Identity, Contact and Medical Data by using Our Services or by corresponding with Us by post, phone, email or otherwise. This includes personal data you provide when you:
Direct interactions
You may give Us your Identity, Contact and Medical Data by using Our Services or by corresponding with Us by post, phone, email or otherwise. This includes personal data you provide when you:
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apply for Our products or Services;
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create an account on Our website or through our applications VITA and/or E+BOOK;
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request marketing to be sent to you;
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enter a promotion/survey; or
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give Us feedback or contact Us.
Automated technologies or interactions
As you interact with Our website or Services, We will automatically collect Technical Data about your equipment, browsing actions and patterns. We use cookies and/or other tracking technologies to distinguish you from other users of the Services and to remember your preferences. This helps Us to provide you with a good experience when you use Our Services and also allows Us to improve Our Services.
Third parties or publicly available sources
We will receive personal data about you from various third parties and public sources as set out below for particular purposes:
Automated technologies or interactions
As you interact with Our website or Services, We will automatically collect Technical Data about your equipment, browsing actions and patterns. We use cookies and/or other tracking technologies to distinguish you from other users of the Services and to remember your preferences. This helps Us to provide you with a good experience when you use Our Services and also allows Us to improve Our Services.
Third parties or publicly available sources
We will receive personal data about you from various third parties and public sources as set out below for particular purposes:
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substitute decision makers or authorised persons (e.g. parent(s), guardian(s), family member(s) etc.); and/or
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healthcare providers (e.g. doctors/clinics) and their authorised users.
Acting on someone else’s behalf?
Should you choose to use for instance E+BOOK’s Family Account services to schedule, manage and maintain appointments with healthcare providers and provide Us with personal data about another person (or persons), you should have been appointed and authorised by such person to act on their behalf.
This includes providing consent to Our processing of their personal data and sensitive personal data; and you provide them with a copy of Our Privacy Policy or with a link thereto.
If for any reason you are concerned as to whether you are permitted to provide Us with the other person’s information, please contact Us before sending Us anything.
Use of Your Personal Data
The purposes for which your personal information are collected and used may include (without limitation) one or more of the following purposes:
Purpose 1: The administration of Our products and Services, including to enable Us to perform Our obligations to you and to provide any relevant Services as discussed with you prior to any subscription of a product or Service.
Legal Basis for Processing 1: For the performance of Our Services or in order to take steps prior to entering into a contract with you.
Purpose 2.1: Provision of Services — like to reply to a question, or tell you that something’s changing.
Purpose 2.2: Keeping your information on record and carrying out other internal business administration.
Legal Basis for Processing 2: For the performance of Our Services and Our legitimate interests in maintaining and developing Our relationship with you.
Purpose 3: Complying with any regulatory or other legal requirements.
Legal Basis for Processing 3: Compliance with Our legal obligations.
Purpose 4.1: Design and provide you with related products and services.
Purpose 4.2: Conduct research and statistical analysis (including use of new technologies).
Purpose 4.3: For any other incidental or associated purposes relating to the above.
Legal Basis for Processing 4:
Our legitimate interests in designing and improving Our products and Services, provide value added services, developing Our business and gaining insight into how Our products are used.
Legal Basis for Processing 1: For the performance of Our Services or in order to take steps prior to entering into a contract with you.
Purpose 2.1: Provision of Services — like to reply to a question, or tell you that something’s changing.
Purpose 2.2: Keeping your information on record and carrying out other internal business administration.
Legal Basis for Processing 2: For the performance of Our Services and Our legitimate interests in maintaining and developing Our relationship with you.
Purpose 3: Complying with any regulatory or other legal requirements.
Legal Basis for Processing 3: Compliance with Our legal obligations.
Purpose 4.1: Design and provide you with related products and services.
Purpose 4.2: Conduct research and statistical analysis (including use of new technologies).
Purpose 4.3: For any other incidental or associated purposes relating to the above.
Legal Basis for Processing 4:
Our legitimate interests in designing and improving Our products and Services, provide value added services, developing Our business and gaining insight into how Our products are used.
Purpose
Legal Basis for Processing
The administration of Our products and Services, including to enable Us to perform Our obligations to you and to provide any relevant Services as discussed with you prior to any subscription of a product or Service.
For the performance of Our Services or in order to take steps prior to entering into a contract with you.
Provision of Services — like to reply to a question, or tell you that something’s changing.
For the performance of Our Services and Our legitimate interests in maintaining and developing Our relationship with you.
Keeping your information on record and carrying out other internal business administration.
Complying with any regulatory or other legal requirements.
Compliance with Our legal obligations.
Design and provide you with related products and services.
Our legitimate interests in designing and improving Our products and Services, provide value added services, developing Our business and gaining insight into how Our products are used.
Conduct research and statistical analysis (including use of new technologies).
For any other incidental or associated purposes relating to the above.
In addition, We will use the personal data you provide to Us, together with other information, to send you direct marketing offers by electronic and non-electronic means including by post, as well as sending you introductions to products and services from carefully selected third parties also by post. Our legal basis for this processing is based on your consent.
We will only use your personal data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Us.
If We need to use your personal data for an unrelated purpose, We will notify you and We will explain the legal basis which allows Us to do so.
Please note that We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Outsourcing
Apricot is outsourcing the storage of data by using third-party cloud service providers who shall not have access to personal data stored in the iCloud except when such access is carried out under the supervision of Apricot or a contractual agreement with the Apricot, whereby clear security and confidentiality requirements and obligations exist and such arrangements shall comply with the requirements under DPP2(3) and DPP4(2) of the Personal Data (Privacy) Ordinance (Cap. 486).
Data Retention
We will retain personal data you provide to Us for as long as you use Our Services and for a period of seven years after the end of the customer relationship, or longer if required by law. There may be specific circumstances where it is necessary for Us to retain your personal data for longer (such as when a dispute arises).
Controlling Your Personal Information
You can stop the collection of information by Us easily by uninstalling Our Services, e.g. VITA or E+BOOK. You may use the standard uninstall procedures as may be available as part of your device or via the mobile apps’ marketplace or network.
When it comes to how We use personal data, you have the right to:
When it comes to how We use personal data, you have the right to:
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request a copy of your personal data (We have the right to charge a reasonable fee to complete this request);
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request that We correct anything that is wrong, or complete any incomplete personal data;
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complain to a data protection authority or another independent regulator about how We are using the personal data.
If you want to exercise your rights, or would like an explanation about these rights, we have explained how you can get in touch in the Contact Us section below. We may monitor or record calls or any other communication We have with you. This might be for training, for security, or to help Us check for quality.
Security
The security of your personal information is very important to Us. We use reasonable administrative, physical and procedural measures to safeguard your personal information against loss, theft and unauthorized access. For example, We limit access to this information to authorized employees and contractors and other third parties who need to know that information in order to operate, develop or improve Our Services.
If we become aware that your personal information has been disclosed in a manner not in accordance with this Privacy Policy, We will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent We know that information) as soon as reasonably possible and as permitted by law.
If we become aware that your personal information has been disclosed in a manner not in accordance with this Privacy Policy, We will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent We know that information) as soon as reasonably possible and as permitted by law.
Lost or Stolen Information
You must promptly notify Us if your personal data is lost, stolen, or used without permission. In such an event, We will remove that personal data from your account and update Our records accordingly within a reasonable time.
Updates and Changes to Privacy Policy
We reserve the right to add to, change, update, or modify this Privacy Policy at any time and you should review it periodically. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of Our Services after We post any modifications to the Privacy Policy on the website or software applications will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If you do not wish to acknowledge or accept any updates or changes to this Privacy Policy, you may cancel your use of Our Services. In all cases, use of information We collect is subject to the Privacy Policy in effect at the time such information is collected.
Direct Marketing
We will send you information about Our products and services and carefully selected third parties.
Additionally, from time to time, We would like to contact you by electronic means with details about products, services and any special offers. We will only do this if you have consented to Us contacting you by electronic means.
And if you change your mind, and/or you would like to opt-out of receiving electronic or non-electronic direct marketing, it is easy to let Us know. Just use one of the options in the Contact Us section.
Additionally, from time to time, We would like to contact you by electronic means with details about products, services and any special offers. We will only do this if you have consented to Us contacting you by electronic means.
And if you change your mind, and/or you would like to opt-out of receiving electronic or non-electronic direct marketing, it is easy to let Us know. Just use one of the options in the Contact Us section.
Contact Us
If you have any questions about this Privacy Policy or Our privacy practices, please contact Us at info@apricot.hk.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, We could refuse to comply with your request in these circumstances.
What We may need from you
We may need to request specific information from you to help Us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up Our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take Us longer than a month if your request is particularly complex or you have made a number of requests. In this case, We will notify you and keep you updated.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, We could refuse to comply with your request in these circumstances.
What We may need from you
We may need to request specific information from you to help Us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up Our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take Us longer than a month if your request is particularly complex or you have made a number of requests. In this case, We will notify you and keep you updated.
Your Legal Rights
You have the right to make a complaint at any time to the office of the Privacy Commissioner for Personal Data (“Commissioner”), the Hong Kong supervisory authority for data protection issues (www.pcpd.org.hk). We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner so please contact Us in the first instance.